FARM BUREAU LIFE VARIABLE ACCOUNT
N-8B-2/A, 2000-03-01
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                       SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D.C. 20549

                                   FORM N-8B-2



                    REGISTRATION STATEMENT OF UNIT INVESTMENT
                           TRUSTS WHICH ARE CURRENTLY
                               ISSUING SECURITIES

                             Dated February 28, 2000



                         Pursuant to Section 8(b) of the
                         Investment Company Act of 1940



                        FARM BUREAU LIFE VARIABLE ACCOUNT
                         (Name of Unit Investment Trust)

                             5400 University Avenue
                           WEST DES MOINES, IOWA 50266
                   (Address of Principal Office of Registrant)

                  Issuer of periodic payment plan certificates
                only for purposes of information provided herein

                               Page 1 of 55 Pages


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                                       I.

                      ORGANIZATION AND GENERAL INFORMATION

1.       (a)      Furnish name of the trust and the Internal Revenue Service
                  Employer Identification Number.

                  Farm Bureau Life Variable Account (the "Variable Account").
                  The Variable Account has no Internal Revenue Service Employer
                  Identification Number.

         (b)      Furnish title of each class or series of securities issued by
                  the trust.

                  Flexible Premium Variable Life Insurance Policy ("VUL") and
                  Flexible Premium Last Survivor Variable Life Insurance Policy
                  ("LSVUL") (together "the Policies")

2.       Furnish name and principal business address and ZIP code and the
         Internal Revenue Service Employer Identification Number of each
         depositor of the trust.

                  Farm Bureau Life Insurance Company (the "Company")
                  5400 University Avenue
                  West Des Moines, Iowa 50266

                  Internal Revenue Service Employer
                  Identification Number: 42-0623913

3.       Furnish name and principal business address and ZIP code and the
         Internal Revenue Service Employer Identification Number of each
         custodian or trustee of the trust indicating for which class or series
         of securities each custodian or trustee is acting.

              The Company will hold in its own custody all of the securities.

4.       Furnish name and principal business address and ZIP code and the
         Internal Revenue Service Employer Identification Number of each
         principal underwriter currently distributing securities of the trust.

              The principal underwriter for distribution of the VUL and LSVUL
policies is:

                  EquiTrust Marketing Services, LLC ("ET Marketing")
                  5400 University Avenue
                  West Des Moines, Iowa 50266

                  Internal Revenue Service Employer


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                  Identification Number:  42-0954364

5.       Furnish name of state or other sovereign power, the laws of which
         govern with respect to the organization of the trust.

                  Iowa

6.       (a)      Furnish the dates of execution and termination of any
                  indenture or agreement currently in effect under the terms of
                  which the trust was organized and issued or proposes to issue
                  securities.

                  The Variable Account was established under the laws of the
                  State of Iowa pursuant to resolutions adopted by the Board of
                  Directors of the Company on March 3, 1987. The Variable
                  Account will continue in existence until the Board of
                  Directors of the Company directs that it be terminated. The
                  Policy will be issued pursuant to the resolution.

         (b)      Furnish the dates of execution and termination of any
                  indenture or agreement currently in effect pursuant to which
                  the proceeds of payments on securities issued or to be issued
                  by the trust are held by the custodian or trustee.

                  Not applicable.

7.       Furnish in chronological order the following information with respect
         to each change of name of the trust since January 1, 1930.

                  The Variable Account has never been known by any other name.

8.       State the date on which the fiscal year of the trust ends.

                  December 31.

MATERIAL LITIGATION

9.       Furnish a description of any pending legal proceedings, material with
         respect to the security holders of the trust by reason of the nature of
         the claim or the amount thereof, to which the trust, the depositor, or
         the principal underwriter is a party or of which the assets of the
         trust are the subject, including the substance of the claims involved
         in such proceeding and the title of the proceeding. Furnish a similar
         statement with respect to any pending administrative proceeding
         commenced by a governmental authority or any such proceeding or legal
         proceeding known to be contemplated by a governmental authority.
         Include any proceeding which, although immaterial itself, is
         representative of, or one of, a group which in the aggregate is
         material.


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         There are no pending administrative proceedings commenced by, or known
         to be contemplated by, a governmental authority and no pending legal
         proceedings, material with respect to prospective purchasers of the
         Policies, to which the Variable Account, the Company or ET Marketing is
         a party or to which the assets of the Variable Account are subject.

                                       II.

                        GENERAL DESCRIPTION OF THE TRUST
                           AND SECURITIES OF THE TRUST

GENERAL INFORMATION CONCERNING THE SECURITIES OF THE TRUST AND THE RIGHTS OF
HOLDERS

10.      Furnish a brief statement with respect to the following matters for
         each class or series of securities issued by the trust:

         (a)      Whether the securities are of the registered or bearer type.

                  The Policies are of the registered type insofar as each Policy
                  is personal to the owner of a Policy ("Policyowner") and the
                  records concerning the Policyowner are maintained by or on
                  behalf of the Company. The Variable Account concurrently has
                  filed separate registration statements on Form S-6 registering
                  the Policies with the Securities and Exchange Commission.
                  Capitalized terms used in this Form N-8B-2 have the same
                  meaning as in both Form S-6 registration statements.

         (b)      Whether the securities are of the cumulative or distributive
                  type.

                  Each Policy is of the cumulative type, providing for no direct
                  distribution of income, dividends or capital gains. Such
                  amounts are not separately identifiable but are reflected in
                  the Net Cash Value or Net Surrender Value upon surrender and
                  in the payment of the death benefit upon the death of the
                  Insured (or last Joint Insured, in an LSVUL, as applicable).

         (c)      The rights of security holders with respect to withdrawal or
                  redemption.

                  The Policyowner may cancel the Policy by delivering or mailing
                  written notice to the Company at its Home Office, and
                  returning the Policy to the Company at its Home Office before
                  midnight of the twentieth day after receipt of the Policy.
                  Notice given by mail and return of the Policy by mail are
                  effective on being postmarked, properly addressed and postage
                  prepaid.

                  The Company will refund, within seven days after receipt of
                  the returned Policy at its Home Office, the greater of
                  premiums paid or the Policy's Cash Value plus an


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                  amount approximately equal to any charges that have been
                  deducted from premiums, Cash Value and the Variable Account.


                  At any time prior to the Maturity Date while the Policy is in
                  force, a Policyowner may surrender the Policy in whole or in
                  part by sending a written request to the Company at its Home
                  Office. A surrender charge equal to the lesser of $25 or 2% of
                  the amount partially or fully surrender will apply under a
                  VUL. (This same calculation will be considered for the partial
                  withdrawal fee in an LSVUL.) In an LSVUL, a surrender charge
                  will apply to any surrender during the first ten Policy Years,
                  as well as during the first ten years following an increase in
                  Specified Amount.


                  The amount payable upon surrender of the Policy is the Net
                  Cash Value, minus the surrender charge, at the end of the
                  Valuation Period during which the request is received. This
                  amount may be paid in a lump sum or under one of the payment
                  options specified in the Policy as requested by the
                  Policyowner. Upon surrender, all insurance in force will
                  terminate.

                  A Policyowner may obtain a portion of the Policy's Net Cash
                  Value. A partial surrender must be at least $500 and cannot
                  exceed the lesser of (i) the Net Cash Value less $500 or (2)
                  90% of the Net Cash Value. If not paid in cash, the surrender
                  charge will be deducted from the Cash Value upon each partial
                  surrender. The Policyowner may request that the proceeds of a
                  partial surrender be paid in a lump sum or under one of the
                  payment options specified in the Policy.

                  A partial surrender will be allocated among the Subaccounts
                  and the Declared Interest Option in accordance with the
                  written instructions of the Policyowner. If no such
                  instructions are received with the request for partial
                  surrender, the partial surrender will be allocated among the
                  Subaccounts and the Declared Interest Option in the same
                  proportion that the Cash Value in each of the Subaccounts and
                  the Cash Value in the Declared Interest Option reduced by any
                  outstanding Policy Debt bears to the total Cash Value reduced
                  by any outstanding Policy Debt on the date the request is
                  received at the Home Office.

                  Partial surrenders will affect both the Policy's Cash Value
                  and the death proceeds payable under the Policy. The Policy's
                  Cash Value will be reduced by the amount of the partial
                  surrender. If the death benefit payable under either death
                  benefit option both before and after the partial surrender are
                  equal to the Cash Value multiplied by the specified amount
                  factor set forth in the Policy, a partial surrender will
                  result in a reduction in death proceeds equal to the amount of
                  the partial surrender, multiplied by the specified amount
                  factor then in effect. If the death benefit is not so affected
                  by the specified amount factor, the reduction in death
                  proceeds will be equal to the partial surrender.


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                  Partial surrenders will reduce the Policy's Specified Amount
                  by the amount of Cash Value surrendered if Option B is in
                  effect at the time of the surrender. If Option A is in effect
                  at the time of the surrender, there will be no effect on
                  Specified Amount. The Specified Amount remaining in force
                  after a partial surrender may not be less than the minimum
                  Specified Amount for the Policy in effect on the date of the
                  partial surrender, as published by the Company. As a result,
                  the Company will not process any partial surrender that would
                  reduce the Specified Amount below this minimum. If increases
                  in the Specified Amount previously have occurred, a partial
                  surrender will first reduce the Specified Amount of the most
                  recent increase, then the next most recent increases
                  successively, then the coverage under the original
                  application. Thus, a partial surrender may affect the amount
                  of the cost of insurance charge.

                  Payment of amounts in connection with a surrender or partial
                  surrender ordinarily will be mailed to the Policyowner within
                  seven (7) days after the Company receives a signed request for
                  withdrawal at its Home Office. Payment may be postponed
                  whenever: (i) the New York Stock Exchange is closed other than
                  customary weekend and holiday closings, or trading on the New
                  York Stock Exchange is restricted as determined by the
                  Securities and Exchange Commission ("Commission"); (ii) the
                  Commission by order permits postponement for the protection of
                  Policyowners; or (iii) an emergency exists, as determined by
                  the Commission, as a result of which disposal of securities is
                  not reasonably practicable or it is not reasonably practicable
                  to determine the value of the net assets of the Variable
                  Account. In addition, requests for surrenders of Cash Value
                  derived from any amount paid by check or draft may be
                  postponed until such time as the Company is satisfied that the
                  check or draft has cleared the bank upon which it was drawn.

         (d)      The rights of security holders with respect to conversion,
                  transfer, partial redemption, and similar matters.

                  A Policyowner may, at any time prior to the Maturity Date
                  while the Policy is in force, convert the Policy to a flexible
                  premium fixed-benefit life insurance policy in a VUL (or
                  flexible premium fixed-benefit last survivor life insurance
                  policy in an LSVUL) by requesting that all of the Cash Value
                  in the Variable Account be transferred to the Declared
                  Interest Option. The Policyowner may exercise this special
                  transfer privilege once each Policy Year. Once a Policyowner
                  exercises the special transfer privilege, all future premium
                  payments will automatically be credited to the Declared
                  Interest Option, until such time as the Policyowner requests a
                  change in allocation. No charge will be imposed for any
                  transfers resulting from the exercise of the special transfer
                  privilege.


                  Policyowners may transfer amounts among the Subaccounts of the
                  Variable Account an unlimited number of times in a Policy
                  Year. Amounts may be


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                  transferred between the Variable Account and the Declared
                  Interest Option only once in a Policy Year. Transfers are made
                  by written request to the Home Office or, if the Policyowner
                  has elected the "Telephone Transfer Authorization" on the
                  supplemental application by calling the Home Office toll-free
                  at (800) 247-4170. The amount of the transfer must be at least
                  $100 or the total Cash Value in the Subaccount or in the
                  Declared Interest Option (reduced, in the case of the Declared
                  Interest Option, by any outstanding Policy Debt), if less than
                  $100. The Company may, at its discretion, waive the $100
                  minimum requirement. The transfer will be effective as of the
                  end of the Valuation Period during which the request is
                  received at the Home Office.


                  The first transfer in each Policy Year will be made without
                  charge; each time amounts are subsequently transferred in that
                  Policy Year, a transfer charge of $25 may be assessed. The
                  transfer charge, unless paid in cash, will be deducted from
                  the amount transferred. Once a Policy is issued, the amount of
                  the transfer charge is guaranteed for the life of the Policy.

                  For purposes of these limitations and charges, all transfers
                  effected on the same day will be considered a single transfer.

                  The Policyowner may obtain Policy Loans, as described in Item
                  21.

                  The Policyowner may make surrenders and partial surrenders, as
                  described in Item 10(c).

         (e)      If the trust is the issuer of periodic payment plan
                  certificates, the substance of the provisions of any indenture
                  or agreement with respect to lapses or defaults by security
                  holders in making principal payments, and with respect to
                  reinstatement.

                  The Policy will lapse if, on a Monthly Deduction Day, the Net
                  Cash Value (or Net Surrender Value after three years in an
                  LSVUL) is insufficient to cover the monthly deduction due and
                  a Grace Period expires without a sufficient payment. The
                  Company allows a 61-day Grace Period for payment of a premium
                  that, when reduced by the premium expense charge, will be at
                  least equal to three times the monthly deduction due on such
                  Monthly Deduction Day. The Grace Period will begin on the date
                  the Company mails notice of the insufficiency to the
                  Policyowner. Failure to make a sufficient payment by the end
                  of the Grace Period will cause the Policy to lapse and
                  terminate without value.

                  Insurance coverage continues during the Grace Period, but the
                  Policy will be deemed to have no Cash Value for purposes of
                  Policy Loans and surrenders during such Grace Period.


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                  If the Insured (or Joint Insureds in an LSVUL, as applicable)
                  dies during the Grace Period, the death proceeds payable
                  during the Grace Period will equal the amount of the death
                  proceeds payable immediately prior to the commencement of the
                  Grace Period, reduced by any due and unpaid monthly
                  deductions.


                  Prior to the Maturity Date, a lapsed Policy may be reinstated
                  at any time within five years of the Monthly Deduction Day
                  immediately preceding the Grace Period which expired without
                  payment of the required premium. Reinstatement is effected by
                  submitting the following items to the Company: (i) a written
                  application for reinstatement signed by the Policyowner and
                  the Insured (or Joint Insureds in an LSVUL, as applicable);
                  (ii) evidence of insurability satisfactory to the Company;
                  (iii) a premium that, after the deduction of the premium
                  expense charge, is at least sufficient to keep the Policy in
                  force for three months; and (iv) an amount equal to the
                  monthly cost of insurance for the two Policy Months prior to
                  lapse.


                  (State law may limit the premium to be paid on reinstatement
                  to an amount less than that described.) To the extent that the
                  first year monthly administrative charge was not deducted for
                  a total of twelve Policy Months prior to lapse, such charge
                  will continue to be deducted following reinstatement of the
                  Policy until such charge has been assessed, both before and
                  after the lapse, for a total of 12 Policy Months. The Company
                  will not reinstate a Policy surrendered for its Cash Value (or
                  Net Surrender Value in an LSVUL).

                  The effective date of the reinstated Policy will be the
                  Monthly Deduction Day coinciding with or next following the
                  date the Company approves the application for reinstatement.

         (f)      The substance of the provisions of any indenture or agreement
                  with respect to voting rights, together with the names of any
                  persons other than security holders given the right to
                  exercise voting rights pertaining to the trust's securities or
                  the underlying securities and the relationship of such persons
                  to the trust.

                  To the extent required by law, the Company will vote the Fund
                  shares held in the Variable Account at regular and special
                  shareholder meetings of the Funds in accordance with
                  instructions received from persons having voting interests in
                  the corresponding Subaccounts. If, however, the Investment
                  Company Act of 1940 or any regulation thereunder should be
                  amended or if the present interpretation thereof should
                  change, and, as a result, the Company determines that it is
                  permitted to vote the Fund shares in its own right, it may
                  elect to do so.

                  The number of votes which a Policyowner has the right to
                  instruct will be calculated separately for each Subaccount.
                  The number of votes which each Policyowner has the right to
                  instruct will be determined by dividing a Policy's


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                  Cash Value in a Subaccount by the net asset value per share of
                  the corresponding Investment Option in which the Subaccount
                  invests. Fractional shares will be counted. The number of
                  votes of the Investment Option which the Policyowner has the
                  right to instruct will be determined as of the date coincident
                  with the date established by that Investment Option for
                  determining shareholders eligible to vote at such meeting of
                  the Fund. Voting instructions will be solicited by written
                  communications prior to such meeting in accordance with
                  procedures established by each Fund. Each person having a
                  voting interest in a Subaccount will receive proxy material,
                  reports and other materials relating to the appropriate
                  Investment Option.

                  The Company will vote Fund shares attributable to the Policies
                  as to which no timely instructions are received (as well as
                  any Fund shares held in the Variable Account which are not
                  attributable to the Policies) in proportion to the voting
                  instructions which are received with respect to all Policies
                  participating in each Investment Option. Voting instructions
                  to abstain on any item to be voted upon will be applied on a
                  PRO RATA basis to reduce the votes eligible to be cast on a
                  matter.

                  Fund shares may also be held by separate accounts of other
                  affiliated and unaffiliated insurance companies. The Company
                  expects that those shares will be voted in accordance with
                  instructions of the owners of insurance policies and contracts
                  issued by those other insurance companies. Voting instructions
                  given by owners of other insurance policies will dilute the
                  effect of voting instructions of Policyowners.

                  The Company provided the start-up capital for the Fund by
                  purchasing $100,000,000 worth of shares. The Company intends
                  to vote these shares in proportion to the voting instructions
                  received from Policyowners.

                  The Company may, when required by state insurance regulatory
                  authorities, disregard voting instructions if the instructions
                  require that the shares be voted so as to cause a change in
                  the sub-classification or investment objective of an
                  Investment Option or to approve or disapprove an investment
                  advisory contract for an Investment Option. In addition, the
                  Company itself may disregard voting instructions in favor of
                  changes initiated by a Policyowner in the investment policy or
                  the investment adviser of an Investment Option if the Company
                  reasonably disapproves of such changes. A change would be
                  disapproved only if the proposed change is contrary to state
                  law or prohibited by state regulatory authorities or the
                  Company determined that the change would have an adverse
                  effect on the General Account in that the proposed investment
                  policy for an Investment Option may result in overly
                  speculative or unsound investments. In the event the Company
                  does disregard voting instructions, a summary of that


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                  action and the reasons for such action will be included in the
                  next annual report to Policyowners.

         (g) Whether security holders must be given notice of any change in:

                  (1)      the composition of the assets of the trust.

                  The Company reserves the right, subject to compliance with
                  applicable law, to make additions to, deletions from, or
                  substitutions for the shares of the Investment Options that
                  are held by the Variable Account or that the Variable Account
                  may purchase. If the shares of an Investment Option are no
                  longer available for investment or if, in its judgement,
                  further investment in any Investment Option should become
                  inappropriate in view of the purposes of the Variable Account,
                  the Company reserves the right to dispose of the shares of any
                  Investment Option of the Fund and to substitute shares of
                  another Investment Option. The Company will not substitute any
                  shares attributable to a Policyowner's Cash Value in the
                  Variable Account without notice to and prior approval of the
                  Securities and Exchange Commission, to the extent required by
                  the Investment Company Act of 1940 or other applicable law.

                  The Company also reserves the right to establish additional
                  subaccounts of the Variable Account, each of which would
                  invest in shares of a new Investment Option with a specified
                  investment objective. New subaccounts may be established when,
                  in the sole discretion of the Company, marketing, tax or
                  investment conditions warrant, and any new subaccounts may be
                  made available to existing Policyowners on a basis to be
                  determined by the Company. Subject to obtaining any approvals
                  or consents required by applicable law, the assets of one or
                  more Subaccounts may be transferred to any other
                  Subaccount(s), or one or more Subaccounts may be eliminated or
                  combined with any other Subaccounts if, in the sole discretion
                  of the Company, marketing, tax, or investment conditions
                  warrant.

                  In the event of any such substitution or change, the Company
                  may, by appropriate endorsement, make such changes in these
                  and other policies as may be necessary or appropriate to
                  reflect such substitution or change. If deemed by the Company
                  to be in the best interests of persons having voting rights
                  under the Policies, the Variable Account may be operated as a
                  management company under the Investment Company Act of 1940,
                  may be deregistered under that Act in the event such
                  registration is no longer required, or, subject to obtaining
                  any approvals or consents required by applicable law, may be
                  combined with other Company separate accounts. To the extent
                  permitted by applicable law, the Company may also transfer the
                  assets of the Variable Account associated with the Policies to
                  another separate account. In addition, the Company may, when
                  permitted by law,


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                  restrict or eliminate any voting rights of Policyowners or
                  other persons who have voting rights as to the Variable
                  Account.

                  (2) the terms and conditions of the securities issued by the
trust.

                  No changes in the terms and conditions of a Policy that affect
                  the Policyowner's rights will be made without notice to the
                  Policyowner to the extent required by law.

                  (3) the provisions of any indenture or agreement of the trust.

                  No notice to or consent from Policyowners is required for any
                  change in the Company's resolution establishing the Variable
                  Account.

                  (4) the identity of the depositor, trustee or custodian.

                  No notice to or consent from Policyowners is required.

         (h)      Whether the consent of security holders is required in order
                  for action to be taken concerning any change in:

                  (1)      the composition of the assets of the trust.

                  Consent of Policyowners is not required when changing the
                  underlying securities of the Variable Account. However, to
                  change such securities, approval of the Commission may be
                  required by Section 26(b) of the 1940 Act.

                  (2) the terms and conditions of the securities issued by the
trust.

                  Except as appropriate to comply with federal or state law or
                  regulation, no change in the terms and conditions of a Policy
                  can be made without consent of the Policyowner.

                  (3) the provisions of any indenture or agreement of the trust.

                  No consent is required.

                  (4)      the identity of the depositor, trustee or custodian

                  No consent is required.

         (i)      Any other principal feature of the securities issued by the
                  trust or any other principal right, privilege or obligation
                  not covered by subdivisions (a) to (g) or by any other item in
                  this form.


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                  (1)      PREMIUM PAYMENTS. Before it will issue a Policy, the
                           Company may require the Policyowner to pay an initial
                           premium that, when reduced by the premium expense
                           charge, will be sufficient to pay the monthly
                           deduction for the first Policy Month.


                           Each Policyowner will determine a planned periodic
                           premium schedule that provides for the payment of a
                           level premium over a specified period of time on a
                           quarterly, semi-annual or annual basis. The Company
                           may, at its discretion, permit planned periodic
                           premium payments to be made on a monthly basis.
                           Periodic reminder notices ordinarily will be sent to
                           the Policyowner for each planned periodic premium.
                           Depending on the duration of the planned periodic
                           premium schedule, the timing of planned payments
                           could affect the tax status of the Policy.

                           The Policyowner is not required to pay premiums in
                           accordance with the planned periodic premium
                           schedule. Furthermore, the Policyowner has
                           considerable flexibility to alter the amount,
                           frequency, and the time period over which planned
                           periodic premiums are paid; however, no planned
                           periodic payment may be less than $100 without the
                           Company's consent.

                           A Policyowner may make unscheduled premium payments
                           at any time prior to the Maturity Date, subject to
                           the minimum and maximum premium limitations described
                           below. Each unscheduled premium payment must be at
                           least $100; however, the Company may, in its
                           discretion, waive this minimum requirement. The
                           Company reserves the right to limit the number and
                           amount of unscheduled premium payments.

                           In no event may the total of all premiums paid, both
                           planned periodic and unscheduled, exceed the
                           applicable maximum premium limitation imposed by
                           federal tax laws. Because the maximum premium
                           limitation is in part dependent upon the Specified
                           Amount for each Policy, changes in the Specified
                           Amount may affect this limitation. If at any time a
                           premium is paid which would result in total premiums
                           exceeding the applicable maximum premium limitation,
                           the Company will only accept that portion of the
                           premium which will make total premiums equal the
                           maximum. Any part of the premium in excess of that
                           amount will be returned and no further premiums will
                           be accepted until allowed by the applicable maximum
                           premium limitation.

                           Payments made by the Policyowner will be treated
                           first as payment of any outstanding Policy Debt
                           unless the Policyowner indicates that the payment
                           should be treated otherwise. Where no indication is
                           made, any portion of


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                           a payment that exceeds the amount of any outstanding
                           Policy Debt will be treated as a premium payment.

                           The Net Premium is the amount available for
                           investment. The Net Premium equals the premium paid
                           less the premium expense charge.

                           In the application for a Policy, the Policyowner can
                           allocate Net Premiums or portions thereof to the
                           Subaccounts of the Variable Account, to the Declared
                           Interest Option, or both. Notwithstanding the
                           allocation in the application, the Net Premiums will
                           first be allocated to the Declared Interest Option if
                           we receive them either 1) before the date we obtain a
                           signed notice of receipt from the Policyowner, or 2)
                           before the end of 25 days after the Delivery Date
                           (the date the Company issues and mails the Policy).
                           Upon the earlier of 1) or 2) above, the Company will
                           automatically allocate the Cash Value in the Declared
                           Interest Option, without charge, among the
                           Subaccounts and the Declared Interest Option. We
                           allocate Net Premiums received on or after 1) or 2)
                           above in accordance with the Policyowner's
                           instructions, to the Variable Account, the Declared
                           Interest Option, or both. The Policyowner does not
                           waive his cancellation privilege by sending the
                           signed notice of receipt and acceptance of the Policy
                           to the Company.


                           The minimum percentage of each premium that may be
                           allocated to any Subaccount or to the Declared
                           Interest Option is 10%; no fractional percentages
                           will be permitted. The allocation for future Net
                           Premiums may be changed without charge at any time
                           while the Policy is in force by providing the Company
                           with written notice on a form acceptable to the
                           Company signed by the Policyowner. The change will
                           take effect on the date the written notice is
                           received at the Home Office and will have no effect
                           on prior Cash Values.


                  (2)      DEATH PROCEEDS. So long as the Policy remains in
                           force, the Policy provides for the payment of death
                           proceeds upon the death of the Insured in a VUL (and
                           upon the last death of the Joint Insureds in an
                           LSVUL, as applicable). Proceeds will be paid to the
                           primary Beneficiary or a contingent Beneficiary. One
                           or more primary Beneficiaries or contingent
                           Beneficiaries may be named. If no Beneficiary
                           survives the Insured, the death proceeds will be paid
                           to the Policyowner or his estate. Death proceeds may
                           be paid in a lump sum or under a payment option. (If
                           the Joint Insureds die simultaneously in an LSVUL,
                           the Company will pay one-half of the death proceeds
                           to each Joint Insured's beneficiary.) To determine
                           the death proceeds, the death benefit will be reduced
                           by any outstanding Policy Debt and increased by any
                           unearned loan interest and any premiums paid after
                           the date of death. Proceeds will ordinarily be


                                       13
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                           mailed to the Policyowner within seven days after
                           receipt by the Company of Due Proof of Death. Payment
                           may, however, be postponed under certain
                           circumstances. The Company pays interest on those
                           proceeds, at an annual rate no less than 3%, or any
                           rate required by law, from the date of death to the
                           date payment is made.


                           Policyowners designate in the initial application one
                           of two death benefit options offered under the
                           Policy. The amount of the death benefit payable under
                           a Policy will depend upon the option in effect at the
                           time of the Insured's death. Under Option A, the
                           death benefit will be equal to the greater of (i) the
                           sum of the current Specified Amount and the Cash
                           Value, or (ii) the Cash Value multiplied by the
                           specified amount factor. Cash Value will be
                           determined as of the end of the Business Day
                           coinciding with or immediately following the date of
                           death. In a VUL, the specified amount factor is 2.50
                           for an Insured Attained Age 40 or below on the date
                           of death. For Insureds with an Attained Age over 40
                           on the date of death, the factor declines with age as
                           shown in the Specified Amount Factor Table in the
                           Policy. In an LSVUL, the specified amount factor is
                           2.50 for a Joint Insureds' Joint Equal Attained Age
                           40 or below on the date of death. For Joint Insureds
                           with a Joint Equal Attained Age over 40 on the date
                           of death, the factor declines with age as shown in
                           the Specified Amount Factor Table in the Policy.

                           Under Option B, the death benefit will be equal to
                           the greater of (i) the current Specified Amount, or
                           (ii) the Cash Value (determined as of the end of the
                           Business Day coinciding with or immediately following
                           the date of death) multiplied by the specific amount
                           factor. The specified amount factor is the same as
                           under Option A.

                           The death benefit option in effect may be changed at
                           any time by sending the Company a written request for
                           the change. The effective date of such a change will
                           be the Monthly Deduction Day coinciding with or
                           immediately following the date the change is approved
                           by the Company.

                           If the death benefit option is changed from Option A
                           to Option B, the death benefit will not change and
                           the current Specified Amount will be increased by the
                           Cash Value on the effective date of the change. If
                           the benefit option is changed from Option B to Option
                           A, the current Specified Amount will be reduced by an
                           amount equal to the Cash Value on the effective date
                           of the change. A change in the death benefit option
                           may not be made if it would result in a Specified
                           Amount which is less than the minimum Specified
                           Amount in effect on the effective date of the change
                           or if after the change the Policy would no longer
                           qualify as life insurance under federal tax law.


                                       14
<PAGE>


                           No charges will be imposed upon a change in death
                           benefit option; however, a change in death benefit
                           option will affect the cost of insurance charges.

                           After a Policy has been in force for one Policy Year,
                           a Policyowner may adjust the existing insurance
                           coverage by increasing or decreasing the Specified
                           Amount. To make a change, the Policyowner must send a
                           written request to the Company at its Home Office.
                           Any change in the Specified Amount may affect the
                           cost of insurance rate and the net amount at risk,
                           both of which will affect a Policyowner's cost of
                           insurance charge. If decreases in the Specified
                           Amount cause the premiums paid to exceed the maximum
                           premium limitations required by federal tax law, the
                           decrease will be limited to the extent necessary to
                           meet these requirements.

                           Any decrease in the Specified Amount will become
                           effective on the Monthly Deduction Day coinciding
                           with or immediately following the date the request is
                           approved by the Company. The decrease will first
                           reduce the Specified Amount provided by the most
                           recent increase, then the next most recent increases
                           successively, then the Specified Amount under the
                           original application. The Specified Amount following
                           a decrease can never be less than the minimum
                           Specified Amount for the Policy in effect on the date
                           of the decrease. A Specified Amount decrease will not
                           reduce the Surrender Charge.


                           To apply for an increase, evidence of insurability
                           satisfactory to the Company must be provided. Any
                           approved increase will become effective on the
                           Monthly Deduction Day coinciding with or immediately
                           following the date the request is approved by the
                           Company. An increase will not become effective,
                           however, if the Policy's Cash Value on the effective
                           date would not be sufficient to cover the deduction
                           for the increased cost of the insurance for the next
                           Policy Month. A Specified Amount increase is subject
                           to its own Surrender Charge.


                  (3)      BENEFITS AT MATURITY. If the Insured is alive and the
                           Policy is in force on the Maturity Date, the Company
                           will pay to the Policyowner the Policy's Cash Value
                           as of the end of the Business Day coinciding with or
                           immediately following the Maturity Date, reduced by
                           any outstanding Policy Debt. Benefits at maturity may
                           be paid in a lump sum or under a payment option. The
                           Maturity Date is Attained Age 95 in a VUL and Joint
                           Equal Attained Age 115 in an LSVUL.


                                       15
<PAGE>


                  (4)      CALCULATION OF CASH VALUE. The Policy provides for
                           the accumulation of Cash Value. Cash Value will be
                           determined on each Business Day. A Policy's Cash
                           Value will reflect a number of factors including Net
                           Premiums paid, partial surrenders, Policy Loans,
                           charges assessed in connection with the Policy, the
                           interest earned on the Cash Value in the Declared
                           Interest Option, and the investment performance of
                           the Subaccounts to which the Cash Value is allocated.
                           There is no guaranteed minimum Cash Value. The Cash
                           Value of the Policy is equal to (1) the sum of the
                           Cash Values in each Subaccount, plus (2) the Cash
                           Value in the Declared Interest Option, including
                           amounts transferred to the Declared Interest Option
                           to secure outstanding Policy Debt.

                           As of the Issue Date, the Policy's Cash Value will
                           equal the Cash Value in the Declared Interest Option,
                           which will equal the initial Net Premium less the
                           monthly deduction made on the Policy Date.
                           Thereafter, the Cash Value in the Declared Interest
                           Option will reflect any interest credited, and any
                           subsequent monthly deductions made on Monthly
                           Deduction Days.

                           On the Business Day coinciding with or immediately
                           following the date the Company receives notice that
                           the Policy has been received, but no later than 25
                           days after the Delivery Date, the Cash Value, all of
                           which is in the Declared Interest Option will be
                           transferred automatically to the Subaccounts and the
                           Declared Interest Option in accordance with the
                           percentage allocation instructions. At the end of
                           each Valuation Period thereafter, the Cash Value in a
                           Subaccount is (i) plus (ii) plus (iii) minus (iv)
                           minus (v) minus (vi) where: (i) is the total
                           Subaccount units represented by the Cash Value at the
                           end of the preceding Valuation Period, multiplied by
                           the Subaccount's Unit Value for the current Valuation
                           Period; (ii) is any Net Premiums received during the
                           current Valuation Period which are allocated to the
                           Subaccount; (iii) is all Cash Values transferred to
                           the Subaccount from the Declared Interest Option or
                           from another Subaccount during the current Valuation
                           Period; (iv) is all Cash Values transferred from the
                           Subaccount to another Subaccount or to the Declared
                           Interest Option during the current Valuation Period,
                           including amounts transferred to the Declared
                           Interest Option to secure Policy Debt; (v) is all
                           partial surrenders from the Subaccount during the
                           current Valuation Period; and (vi) is the portion of
                           any monthly deduction charged to the Subaccount
                           during the current Valuation Period to cover the
                           Policy Month following the Monthly Deduction Day.

                           The Policy's total Cash Value in the Variable Account
                           equals the sum of the Policy's Cash Value in each
                           Subaccount.


                                       16
<PAGE>


                           Each Subaccount has a Unit Value. When Net Premiums
                           are allocated to, or other amounts are transferred
                           into, a Subaccount, a number of Units are purchased
                           based on the Unit Value of the Subaccount as of the
                           end of the Valuation Period during which the transfer
                           is made. Likewise, when amounts are transferred out
                           of a Subaccount, Units are redeemed in a similar
                           manner. On any day, a Policy's Cash Value in a
                           Subaccount is equal to the number of Units held in
                           such Subaccount, multiplied by the Unit Value of such
                           Subaccount on that date.

                           For each Subaccount, the Unit Value was initially set
                           at $10 when the Subaccount first purchased shares of
                           the designated Investment Option. The Unit Value for
                           each subsequent Valuation Period is calculated by
                           dividing (a) by (b) where (a) is:

                           (1) the value of the net assets of the Subaccount at
                           the end of the preceding Valuation Period, plus (2)
                           the investment income and capital gains, realized or
                           unrealized, credited to the net assets of that
                           Subaccount during the Valuation Period for which the
                           Unit Value is being determined, minus (3) the capital
                           losses, realized or unrealized, charged against those
                           assets during the Valuation Period, minus (4) any
                           amount charged against the Subaccount for taxes, or
                           any amount set aside during the Valuation Period by
                           the Company as a provision for taxes attributable to
                           the operation or maintenance of that Subaccount; and
                           minus (5) a charge no greater than .0024548% of the
                           average daily net assets of the Subaccount for each
                           day in the Valuation Period. This corresponds to an
                           annual rate of .90% of the average daily net assets
                           of the Subaccount for mortality and expense risks
                           incurred in connection with the Policies; and

                           (b) is the number of units outstanding at the end of
                           the preceding Valuation Period.

                           The Unit Value for a Valuation Period applies for
                           each day in the period. The assets in the Variable
                           Account will be valued at their fair market value in
                           accordance with accepted accounting practices and
                           applicable laws and regulations.

                  (5)      BUSINESS DAY AND VALUATION PERIOD. A Business Day is
                           each day that the New York Stock Exchange is open for
                           trading, except for the day after Thanksgiving, the
                           Tuesday after Christmas (in 2000) and any day on
                           which the Home Office is closed because of a
                           weather-related or comparable type of emergency. A
                           Valuation Period is the period between the close of
                           business (3:00 p.m. central time) on a Business Day
                           and the close of business on the next Business Day.


                                       17
<PAGE>


                  (6)      LOAN PROVISIONS. SEE Item 21.

                  (7)      PAYMENT OF BENEFITS. The Company will usually mail
                           proceeds of complete surrenders, partial surrenders
                           and Policy Loans within seven days after the
                           Policyowner's signed request is received at the Home
                           Office. The Company will usually mail death proceeds
                           within seven days after receipt of Due Proof of
                           Death, and maturity benefits within seven days of the
                           Maturity Date. However, payment of any amount upon
                           complete surrender or partial surrender, payment of
                           any policy loan, and payment of death proceeds or
                           benefits at maturity may be postponed whenever: (a)
                           the New York Stock Exchange is closed other than
                           customary weekend and holiday closings, or trading on
                           the New York Stock Exchange is restricted as
                           determined by the Commission; (b) the Commission by
                           order permits postponement for the protection of
                           Policyowners; or (c) an emergency exists, as
                           determined by the Commission, as a result of which
                           disposal of the securities is not reasonably
                           practicable or it is not reasonably practicable to
                           determine the value of the net assets of the Variable
                           Account.

                           Payments under the Policy which are derived from any
                           amount paid to the Company by check or draft may be
                           postponed until such time as the Company is satisfied
                           that the check or draft has cleared the bank upon
                           which it is drawn.

                  (8)      PAYMENT OPTIONS. Death proceeds and Cash Value paid
                           at maturity, or upon complete or partial surrender
                           of a Policy, may be paid in whole or in part under a
                           payment option. There are currently five payment
                           options available. Payments may also be made under
                           any new payment option available at the time proceeds
                           become payable. In addition, proceeds may be paid in
                           any other manner acceptable to the Company.

                           An option may be designated in the application or by
                           notifying the Company in writing at its Home Office.
                           During the lifetime of the Insured, the Policyowner
                           may select a payment option; in addition, during that
                           time the Policyowner may change a previously selected
                           option by sending written notice to the Company
                           requesting the cancellation of the prior option and
                           the designation of a new option. If the Policyowner
                           has not chosen an option prior to the Insured's
                           death, the Beneficiary may choose an option. The
                           Beneficiary may change a payment option by sending a
                           written request to the Company, provided that a prior
                           option chosen by the Policyowner is not in effect.

                           If no option is chosen, the Company will pay the
                           proceeds of the Policy in one sum. The Company will
                           also pay the proceeds in one sum if (i) the


                                       18
<PAGE>


                           proceeds are less than $2,000; (ii) periodic payments
                           would be less than $20; or (iii) the payee is an
                           assignee, estate, trustee, partnership, corporation,
                           or association.

                           Amounts paid under a payment option are paid pursuant
                           to a payment contract. Proceeds applied under a
                           payment option earn interest at a rate guaranteed to
                           be no less than 3% compounded yearly. The Company may
                           be crediting higher interest rates on the effective
                           date of the payment contract. The Company may, but is
                           not obligated to, declare additional interest to be
                           applied to such funds.

                           If a payee dies, any remaining payments will be paid
                           to a contingent payee. At the death of the last
                           payee, the commuted value of any remaining payments
                           will be paid to the last payee's estate. A payee may
                           not withdraw funds under a payment option unless the
                           Company has agreed to such withdrawal in the payment
                           contract. The Company reserves the right to defer a
                           withdrawal for up to six months and to refuse to
                           allow partial surrenders of less than $250.

                           Payments under Options 2, 3, 4 or 5 will begin as of
                           the date of the Insured's death, on complete or
                           partial surrender, or on the Maturity Date. Payments
                           under Option 1 will begin at the end of the first
                           interest period after the date proceeds are otherwise
                           payable.

                           The options currently available are:

                                    Option 1 -- Interest Income. Periodic
                                    payments of interest earned from the
                                    proceeds will be paid. Payments can be
                                    annual, semiannual, quarterly or monthly,
                                    as-selected by the payee, and will begin at
                                    the end of the first period chosen. Proceeds
                                    left under this plan will earn interest at a
                                    rate determined by the Company, in no event
                                    less than 3% compounded yearly. The payee
                                    may withdraw all or part of the proceeds at
                                    any time.

                                    Option 2 -- Income for a Fixed Term.
                                    Periodic payments will be made for a fixed
                                    term not longer than 30 years. Payments can
                                    be annual, semi-annual, quarterly or
                                    monthly. Guaranteed amounts payable under
                                    the plan will earn interest at a rate
                                    determined by the Company, in no event less
                                    than 3% compounded yearly.

                                    Option 3 -- Life Income with Term Certain.
                                    Equal periodic payments will be made for a
                                    guaranteed minimum period elected. If the
                                    payee lives longer than the minimum period,
                                    payments will continue for his or her life.
                                    The minimum period can be 0, 5, 10,


                                       19
<PAGE>


                                    15 or 20 years. Guaranteed amounts payable
                                    under this plan will earn interest at a rate
                                    determined by the Company, in no event less
                                    than 3% compounded yearly.

                                    Option 4 -- Income of a Fixed Amount. Equal
                                    periodic payments of a definite amount will
                                    be paid. Payments can be annual,
                                    semi-annual, quarterly or monthly. The
                                    amount paid each period must be at least $20
                                    for each $1,000 of proceeds. Payments will
                                    continue until the proceeds are exhausted.
                                    The last payment will equal the amount of
                                    any unpaid proceeds. Unpaid proceeds will
                                    earn interest at a rate determined by the
                                    Company, in no event less than 3% compounded
                                    yearly.

                                    Option 5 -- Joint and Two-Thirds Survivor
                                    Monthly Life Income. Equal monthly payments
                                    will be made for as long as two payees live.
                                    The guaranteed amount payable under this
                                    plan will earn interest at a minimum rate of
                                    3% compounded yearly. When one payee dies,
                                    payments of two-thirds of the original
                                    monthly payment will be made to the
                                    surviving payee. Payments will stop when the
                                    surviving payee dies.

                  (9)      ADDITIONAL INSURANCE BENEFITS. Subject to certain
                           requirements, one or more of the following additional
                           insurance benefits may be added to a Policy by rider:
                           (i) Cost of Living Increase; (ii) Waiver of Charges;
                           (iii) Other Adult Universal Life Insurance; (iv)
                           Children's Term Insurance; and (v) Guaranteed
                           Insurability Option in a VUL and (i) Last Survivor
                           Universal Cost of Living Increase; (ii) Universal
                           Term Life Insurance; and (iii) Estate Protector
                           4-Year Non-Renewable Last Survivor Term in an LSVUL.
                           The cost of any additional insurance benefits will be
                           deducted as part of the monthly deduction.

INFORMATION CONCERNING THE SECURITIES UNDERLYING THE TRUST'S SECURITIES

11.      Describe briefly the kind or type of securities comprising the unit of
         specified securities in which security holders have an interest. (If
         the unit consists of a single security issued by an investment company,
         name such investment company and furnish a description of the type of
         securities comprising the portfolio of such investment company.)

         The Variable Account invests in shares of the Investment Options. The
         Investment Options currently include the Value Growth Portfolio, High
         Grade Bond Portfolio, High Yield Bond Portfolio, Money Market Portfolio
         and Blue chip Portfolio of EquiTrust Variable Insurance Series Fund,
         the VIP Contrafund Portfolio, VIP Growth Portfolio, VIP Growth & Income
         Portfolio, VIP Index 500 Portfolio and VIP Overseas Portfolio of
         Fidelity Variable Insurance Products Fund; the International Stock
         Portfolio of T. Rowe


                                       20
<PAGE>


         Price International Series, Inc. and the Mid-Cap Growth Portfolio, New
         America Growth Portfolio and Personal Strategy Portfolio of T. Rowe
         Price Equity Series, Inc. The Variable Account may, in the future,
         provide for additional investment options. Each Investment Option has
         its own investment objectives and the income and losses for each
         Investment Option will be determined separately.

         The investment objectives and policies of each Investment Option,
         including a description of risks and other information, may be found in
         the prospectus for each Investment Option. There is no assurance that
         any Investment Option will achieve its stated objectives.

12.      If the trust is the issuer of periodic payment plan certificates and if
         any underlying securities were issued by another investment company,
         furnish the following information for each such company:

         (a)      Name of company.

         (b)      Name and principal business address of depositor.

         (c)      Name and principal business address of trustee or custodian.

         (d)      Name and principal business address of principal underwriter.

         (e)      The period during which the securities of such company have
                  been the underlying securities.

         The name, address, custodian, and principal underwriter for each
         Investment Option, where applicable, may be found in the prospectus for
         each Investment Option.

INFORMATION CONCERNING LOADS, FEES, CHARGES AND EXPENSES

13.      (a)      Furnish the following information with respect to each
                  load, fee, expense or charge to which (1) principal payments,
                  (2) underlying securities, (3) distributions, (4) cumulated or
                  reinvested distributions or income, and (5) redeemed or
                  liquidated assets of the trust's securities are subject:

                           (A)  the nature of such load, fee, expense or charge;

                           (B)      the amount thereof;

                           (C)      the name of the person to whom such amounts
                                    are paid and his relationship to the trust;

                           (D)      the nature of the services performed by such
                                    person in consideration for such load, fee,
                                    expense or charge.


                                       21
<PAGE>


                  (1)      PRINCIPAL PAYMENTS.

                           PREMIUM EXPENSE CHARGE. The Net Premium equals the
                           premium paid less a premium expense charge. In a VUL,
                           the premium expense charge is equal to a sales charge
                           of 5% and a premium tax of 2%, while in an LSVUL, the
                           premium expense charge is equal to a maximum of 7% of
                           premium up to the Minimum Initial Premium, and 2% of
                           each premium in excess of the Minimum Initial
                           Premium. The premium expense charge is used to
                           compensate the Company for expenses incurred in
                           connection with the distribution of the Policies and
                           for premium taxes imposed by various states and
                           subdivisions thereof.

                  (2)      UNDERLYING SECURITIES.

                           The investment advisory fee and other expenses
                           applicable to each Investment Option is described in
                           the prospectus for each Investment Option.

                  (3)      DISTRIBUTIONS.

                           No load, fee, expense or charge is assessed in
                           connection with distributions.

                  (4)      CUMULATED OR REINVESTED DISTRIBUTIONS OR INCOME.

                           All income and other distributions earned by the
                           Variable Account are reinvested, without charge, at
                           net asset value in shares of the Portfolio making the
                           distribution.

                  (5)      REDEEMED OR LIQUIDATED ASSETS.

                           To compensate the Company for costs incurred in
                           accomplishing a surrender, a surrender charge equal
                           to the lesser of $25 or 2.0% of the amount partially
                           or fully surrendered will apply to under a VUL. (This
                           same calculation will be considered for the partial
                           withdrawal fee in an LSVUL.) In an LSVUL, a surrender
                           charge will apply to any surrender during the first
                           ten Policy Years, as well a during the first ten
                           years following an increase in Specified Amount. If
                           not paid in cash, the surrender charge will be
                           deducted from the remaining Cash Value.

         (b)      For each installment payment type of periodic payment plan
                  certificate of the trust, furnish the following information
                  with respect to sales load and other deductions from principal
                  payments.


                                       22
<PAGE>


                  SEE answer to Item 13(a) for a description of the deductions
                  for sales load and other deductions from payments.

         (c)      State the amount of total deductions as a percentage of the
                  net amount invested for each type of security issued by the
                  trust. State each different sales charge available as a
                  percentage of the public offering price and as a percentage of
                  the net amount invested. List any special purchase plans or
                  methods established by rule or exemptive order that reflect
                  scheduled variations in, or elimination of, the sales load;
                  and identify each class of individuals or transactions to
                  which such plans apply.

                  The amount of sales load as a percentage of premiums paid is
                  contained in Item 13(a).

         (d)      Explain fully the reasons for any difference in the price at
                  which securities are offered generally to the public, and the
                  price at which securities are offered for any class of
                  transactions to any class or group of individuals, including
                  officers, directors, or employees of the depositor, trustee,
                  custodian or principal underwriter.

                  Not applicable.

         (e)      Furnish a brief description of any loads, fees, expenses, or
                  charges not covered in Item 13(a) which may be paid by
                  security holders in connection with the trust or its
                  securities.

                  (1)      MONTHLY DEDUCTION.

                           Charges will be deducted monthly from the Cash Value
                           of each Policy ("monthly deduction") to compensate
                           the Company for the cost of insurance coverage and
                           any additional benefits added by rider, for
                           underwriting and start-up expenses in connection with
                           issuing a Policy, and for certain administrative
                           costs. The monthly deduction will be deducted on the
                           Policy Date and on each Monthly Deduction Day. It
                           will be deducted from the Declared Interest Option
                           and each Subaccount in the same proportion that the
                           Policy's Net Cash Value in the Declared Interest
                           Option and the Policy's Cash Value in each Subaccount
                           bear to the total Net Cash Value of the Policy. For
                           purposes of making deductions from the Declared
                           Interest Option and the Subaccounts, Cash Values will
                           be determined as of the end of the Business Day
                           coinciding with or immediately following the Monthly
                           Deduction Day. Because portions of the monthly
                           deduction, such as the cost of insurance, can vary
                           from month to month, the monthly deduction itself
                           will vary in amount from month to month.


                                       23
<PAGE>


                           The monthly deduction will be made on the Business
                           Day coinciding with or immediately following each
                           Monthly Deduction Day and will equal: (a) the cost of
                           insurance for the Policy; plus (b) the cost of any
                           optional insurance benefits added by rider; plus (c)
                           the monthly policy expense charge(s).

                           During the first twelve Policy Months and during the
                           twelve Policy Months immediately following an
                           increase in Specified Amount, the monthly deduction
                           will include a first year monthly administrative
                           charge.

                           COST OF INSURANCE. This charge is designed to
                           compensate the Company for the anticipated cost of
                           paying death proceeds to Beneficiaries of those
                           Insureds who die prior to the Maturity Date. The cost
                           of insurance is determined on a monthly basis, and is
                           determined separately for the initial Specified
                           Amount and for any subsequent increases in Specified
                           Amount. The Company will determine the monthly cost
                           of insurance charge by dividing the applicable cost
                           of insurance rate or rates by 1,000 and multiplying
                           the result by the net amount at risk for each Policy
                           Month.

                           NET AMOUNT AT RISK. Under Option A the net amount at
                           risk for a Policy Month is equal to (a) divided by
                           (b), and under Option B the net amount at risk for a
                           Policy Month is equal to (a) divided by (b), minus
                           (c), where: (a) is the Specified Amount; (b) is
                           1.0032737; and (c) is the Cash Value.

                           The Specified Amount and the Cash Value will be
                           determined as of the end of the Business Day
                           coinciding with or immediately following the Monthly
                           Deduction Day.

                           The net amount at risk is determined separately for
                           the initial Specified Amount and any increases in
                           Specified Amount. In determining the net amount at
                           risk for each Specified Amount, the Cash Value will
                           be first considered a part of the initial Specified
                           Amount. If the Cash Value exceeds the initial
                           Specified Amount, it will be considered to be a part
                           of any increase in the Specified Amount in the same
                           order as the increases occurred.

                           COST OF INSURANCE RATE. The cost of insurance rate
                           for the initial Specified Amount will be based on the
                           Insured's sex, premium class, and Attained Age (or
                           Joint Insureds' sex, premium class and Joint Equal
                           Age, as applicable). For any increase in Specified
                           Amount, the cost of insurance rate will be based on
                           the Insured's sex, premium class, and age nearest
                           birthday on the effective date of the increase.
                           Actual cost of insurance rates may change and the
                           actual monthly cost of insurance rates will be


                                       24
<PAGE>


                           determined by the Company based on its expectations
                           as to future mortality experience. However, the
                           actual cost of insurance rates will never be greater
                           than the guaranteed maximum cost of insurance rates
                           set forth in the Policy. These guaranteed rates are
                           based on the 1980 Commissioners' Standard Ordinary
                           Non-Smoker and Smoker Mortality Table. Current cost
                           of insurance rates are generally less than the
                           guaranteed maximum rates. Any change in the cost of
                           insurance rates will apply to all persons of the same
                           age, sex, and premium class whose Policies have been
                           in force the same length of time.


                           The cost of insurance rates generally increase as the
                           Insured's Attained Age increases. The premium class
                           of an Insured also will affect the cost of insurance
                           rate. The Company currently places Insureds into a
                           standard premium class or into premium classes
                           involving a higher mortality risk. In an otherwise
                           identical Policy, Insureds in the standard premium
                           class will have a lower cost of insurance rate than
                           those in premium classes involving higher mortality
                           risk. The standard premium class is also divided into
                           two categories: tobacco and non-tobacco. The Company
                           may offer preferred classes in addition to the
                           standard tobacco and non-tobacco classes. Non-tobacco
                           Insureds will generally have a lower cost of
                           insurance rate than similarly situated Insureds who
                           use tobacco, and preferred plus Insured's will
                           generally have a lower cost of insurance rate than
                           similarly situated standard Insureds.


                           The cost of insurance rate is determined separately
                           for the initial Specified Amount and for the amount
                           of any increase in Specified Amount. In calculating
                           the cost of insurance charge, the rate for the
                           premium class on the Policy Date will be applied to
                           the net amount at risk for the initial Specified
                           Amount; for each increase in Specified Amount, the
                           rate for the premium class applicable to the increase
                           will be used. However, if the death benefit is
                           calculated as the Cash Value times the specified
                           amount factor, the rate for the premium class for the
                           most recent increase that required evidence of
                           insurability will be used for the amount of death
                           benefit in excess of the total Specified Amount.

                           ADDITIONAL INSURANCE BENEFITS. The monthly deduction
                           will include charges for any additional benefits
                           provided by rider.

                           MONTHLY POLICY EXPENSE CHARGE. The Company has
                           primary responsibility for the administration of the
                           Policy and the Variable Account. Policy expenses
                           include premium billing and collection,
                           recordkeeping, processing death benefit claims, cash
                           surrenders or withdrawals and Policy changes, and
                           reporting and overhead costs. As reimbursement for
                           Policy expenses related to the maintenance of each


                                       25
<PAGE>


                           Policy and the Variable Account, the Company assesses
                           a monthly policy expense charge against each Policy.
                           This charge is guaranteed not to exceed $3 per Policy
                           Month in a VUL and $14 per Policy Month in an LSVUL.
                           In an LSVUL, the Company applies an additional charge
                           guaranteed not to exceed $0.05 per $1,000 of
                           Specified Amount.


                           FIRST YEAR MONTHLY ADMINISTRATIVE CHARGE. A monthly
                           administrative charge will be deducted from Cash
                           Value as part of the monthly deduction during the
                           first twelve Policy Months and during the twelve
                           Policy Months immediately following an increase in
                           Specified Amount. The charge will compensate the
                           Company for first year underwriting, processing and
                           start-up expenses incurred in connection with the
                           Policy and the Variable Account. These expenses
                           include the cost of processing applications,
                           conducting medical examinations, determining
                           insurability and the Insured's premium class, and
                           establishing policy records. In a VUL, the first year
                           monthly administrative charge per $1,000 of Specified
                           Amount depends on the Specified Amount of the Policy
                           and the age of the Insured. In an LSVUL, the first
                           year monthly administrative charge is guaranteed not
                           to exceed $0.14 per $1,000 of Specified Amount.


                           FIRST YEAR MONTHLY EXPENSE CHARGE. In an LSVUL, a
                           monthly expense charge guaranteed not to exceed $14
                           per Policy Month will be deducted from Cash Value as
                           part of the monthly deduction during the first 12
                           Policy Months.

                  (2)      TRANSACTION CHARGES.

                           A transfer charge of $25 may be imposed for the
                           second and each subsequent transfer during a Policy
                           Year to compensate the Company for the costs in
                           effectuating the transfer. Once a Policy is issued,
                           the amount of this charge is guaranteed for the life
                           of the Policy. The transfer charge, unless paid in
                           cash, will be deducted from the amount transferred.
                           The transfer charge will not be imposed on transfers
                           that occur as a result of Policy Loans, the exercise
                           of the special transfer privilege, or the
                           reallocation of Cash Value to the Subaccounts and the
                           Declared Interest Option following acceptance of the
                           Policy by the Policyowner.

                           Currently there is no charge for changing the net
                           premium allocation instructions.

                  (3)      MORTALITY AND EXPENSE RISK CHARGE.


                                       26
<PAGE>


                           The Company deducts a daily mortality and expense
                           risk charge from each Subaccount at an annual rate
                           of up to .90% of the average daily net assets of
                           the Subaccounts.

                           The mortality risk assumed by the Company is that
                           Insureds may die sooner than anticipated and that
                           therefore the Company will pay an aggregate amount of
                           life insurance proceeds greater than anticipated. The
                           expense risk assumed is that expenses incurred in
                           issuing and administering the Policies will exceed
                           the amounts realized from the administrative charges
                           assessed against the Policies.

                  (4)      FEDERAL TAXES.

                           Currently no charge is made to the Variable Account
                           for federal income taxes that may be attributable to
                           the Variable Account. The Company may, however, make
                           such a charge in the future. Charges for other taxes,
                           if any, attributable to the Variable Account may also
                           be made.

                  (5)      INVESTMENT OPTION EXPENSES.

                           The value of net assets of the Variable Account will
                           reflect the investment advisory fee and other
                           expenses incurred by the Fund.

         (f)      State whether the depositor, principal underwriter, custodian
                  or trustee, or any affiliated person of the foregoing may
                  receive profits or other benefits not included in answer to
                  Item 13(a) or 13(d) through the sale or purchase of the
                  trust's securities or underlying securities or interests in
                  underlying securities, and describe fully the nature and
                  extent of such profits or benefits.

                  Neither the Company nor the principal underwriter nor any
                  affiliated person of the foregoing may receive any profit or
                  any other benefit from premium payments under the Policy or
                  the investments held in the Variable Account not included in
                  answer to Item 13(a) or (d) through the sale or purchase of
                  the Policy or shares of the Investment Options, except that
                  (1) the Company may receive a profit to the extent that the
                  cost of insurance built into the Policy exceeds the actual
                  cost of insurance needed to pay benefits; (2) favorable
                  mortality or expense experience may cause the insurance
                  provided under the Policy to be profitable to the Company; (3)
                  the Company will compensate certain others, including the
                  Company agents, for services rendered in connection with the
                  distribution of the Policy, as described in Item 38, but such
                  payments will be made from the Company's General Account; and
                  (4) the Adviser will receive an advisory fee from the Fund, as
                  described in Item 13(a)(2).


                                       27
<PAGE>


         (g)      State the percentage that the aggregate annual charges and
                  deductions for maintenance and other expenses of the trust
                  bear to the dividend and interest income from the trust
                  property during the period covered by the financial statements
                  filed herewith.

                  Not applicable.

INFORMATION CONCERNING THE OPERATIONS OF THE TRUST

14.      Describe the procedure with respect to applications (if any) and the
         issuance and authentication of the trust's securities, and state the
         substance of the provisions of any indenture or agreement pertaining
         thereto.

         Before it will issue a Policy, the Company must receive a completed
         application and an initial premium at its Home Office. A Policy
         ordinarily will be issued only for Insureds who are 0 to 80 years of
         age at their birthday nearest the Policy Date in a VUL, and for Joint
         Insured who have a Joint Equal Age of 18 to 85 years of age at their
         last birthday in an LSVUL, who supply satisfactory evidence of
         insurability to the Company.


         Acceptance is subject to the Company's underwriting rules and the
         Company may, in its sole discretion, reject any application or premium
         for any reason. The minimum Specified Amount for which a Policy will be
         issued is normally $25,000 in a VUL and $100,000 in an LSVUL, although
         the Company may in its discretion issue Policies with Specified Amounts
         of less than $25,000 or $100,000, respectively.

         The Policy Date will be the later of (i) the date of the initial
         application, or (ii) if additional medical or other information is
         required pursuant to the Company's underwriting rules, the date all
         such additional information is received by the Company at its Home
         Office. The Policy Date may also be any other date mutually agreed to
         by the Company and the Policyowner. If the later of (i) and (ii) above
         is the 29th, 30th or 31st of any month, the Policy Date will be the
         28th of such month. The Policy Date is the date used to determine
         Policy Years, Policy Months, and Policy Anniversaries. The Policy Date
         may, but will not always, coincide with the effective date of insurance
         coverage under the Policy.

         The effective date of insurance coverage under the Policy will be the
         latest of (i) the Policy Date, (ii) if an amendment to the initial
         application is required pursuant to the Company's underwriting rules,
         the date the Insured signs the last such amendment, or (iii) the date
         on which the full initial premium is received by the Company at its
         Home Office.

15.      Describe the procedure with respect to the receipt of payments from
         purchasers of the trust's securities and the handling of the proceeds
         thereof, and state the substance of the provisions of any indenture or
         agreement pertaining thereto.


                                       28
<PAGE>


         Before it will issue a Policy, the Company may require the Policyowner
         to pay an initial premium that, that, when reduced by the premium
         expense charge, will be sufficient to pay the monthly deduction for the
         first Policy Month. Premiums are payable at the Company's Home Office.
         SEE ALSO Items 13(a), 14-16 and 18.

         The Policyowner has considerable flexibility to alter the amount,
         frequency, and time period over which premiums are paid. The schedule
         of planned periodic premiums is not mandatory and, subject to the
         limitations described below, the Policyowner may make unscheduled
         premium payments, skip periodic premium payments and change the
         schedule of planned periodic premiums.

         In no event may the total of all premiums paid, both planned periodic
         and unscheduled, exceed the current maximum premium limitations
         established by federal tax laws. If at any time a premium is paid which
         would result in total premiums exceeding the current maximum premium
         limitation, the Company will only accept that portion of the premium
         which will make total premiums equal the maximum. Any part of the
         premium in excess of that amount will be returned and no further
         premiums will be accepted until allowed by the applicable maximum
         premium limitations.

16.      Describe the procedure with respect to the acquisition of underlying
         securities and the disposition thereof, and state the substance of the
         provisions of any indenture or agreement pertaining thereto.

         The Variable Account purchases or redeems shares of the Fund based on a
         netting of all transactions for that day, including the amount of Net
         Premiums invested in the Variable Account, Policy Loans, loan
         repayments, payments upon surrender, charges, and the payment of
         benefits to be effected on that day.

17.      (a)      Describe the procedure with respect to withdrawal or
                  redemption by security holders.

                  The procedures with respect to surrenders or redemption of
                  security holders are described in response to Items 10(c),
                  (d), (e) and (i).

         (b)      Furnish the names of any persons who may redeem or repurchase,
                  or are required to redeem or repurchase, the trust's
                  securities or underlying securities from security holders, and
                  the substance of the provisions of any indenture or agreement
                  pertaining thereto.

                  The Company is required to process all surrender requests as
                  described in Item 10(c). The Fund will redeem its shares upon
                  the Company's request in accordance with the Investment
                  Company Act of 1940. Redeemed shares may later be reissued.


                                       29
<PAGE>


         (c)      Indicate whether repurchased or redeemed securities will be
                  canceled or may be resold.

                  A Policy, once completely surrendered, may not be resold or
                  reinstated.

18.      (a)      Describe the procedure with respect to the receipt, custody
                  and disposition of the income and other distributable funds of
                  the trust and state the substance of the provisions of any
                  indenture or agreement pertaining thereto.

                  All dividend and capital gains distributions of the Investment
                  Option will be automatically reinvested in shares of the
                  distributing Investment Option at its net asset value on the
                  record date.

         (b)      Describe the procedure, if any, with respect to the
                  reinvestment of distributions to security holders and state
                  the substance of the provisions of any indenture or agreement
                  pertaining thereto.

                  Not applicable.

         (c)      If any reserves or special funds are created out of income or
                  principal, state with respect to each such reserve or fund the
                  purpose and ultimate disposition thereof, and describe the
                  manner of handling of same.

                  Net Premiums placed in the Variable Account constitute certain
                  reserves for benefits under the Policy.

         (d)      Submit a schedule showing the periodic and special
                  distributions which have been made to security holders during
                  the three years covered by the financial statements filed
                  herewith. State for each such distribution the aggregate
                  amount and amount per share. If distributions from sources
                  other than current income have been made, identify each such
                  other source and indicate whether such distribution represents
                  the return of principal payments to security holders. If
                  payments other than cash were made, describe the nature
                  thereof, the account charged and the basis of determining the
                  amount of such charge.

                  No distributions have been made.

19.      Describe the procedure with respect to the keeping of records and
         accounts of the trust, the making of reports and the furnishing of
         information to security holders, and the substance of the provisions of
         any indenture or agreement pertaining thereto.

         The Company has primary responsibility for the administration of the
         Policy and the Variable Account. Administrative expenses include
         premium billing and collection; recordkeeping; processing death benefit
         claims, cash surrenders and Policy changes; and


                                       30
<PAGE>


         reporting and overhead costs. As reimbursement for administrative
         expenses related to the maintenance of each Policy and the Variable
         Account, the Company assesses a monthly policy expense charge against
         each Policy.

         The Company may administer the Policy itself. The Company may purchase
         administrative services from such sources (including affiliates) as may
         be available. Such services will be acquired on a basis which, in the
         Company's sole discretion, affords the best services at the lowest
         cost. The Company reserves the right to select a company to provide
         services which the Company deems, in its sole discretion, is the best
         able to perform such services in a satisfactory manner even though the
         costs for such services may be higher than would prevail elsewhere.

         The Company will send such reports as are required by the Investment
         Company Act of 1940 and regulations promulgated thereunder.

         The Company will mail to the Policyowner, at least once each year, an
         annual report. The annual report will show the current death benefit,
         the Cash Value in each Subaccount and in the Declared Interest Option,
         outstanding Policy Debt and premiums paid, partial surrenders or
         surrenders made and charges assessed since the last report. The report
         will also include any other information required by state law or
         regulation. Each person having a voting interest in a Subaccount will
         receive proxy material, reports, and other materials relating to the
         corresponding Investment Option.

20.      State the substance of the provisions of any indenture or agreement
         concerning the trust with respect to the following:

         (a)      Amendments to such indenture or agreement.

                  Not applicable.

         (b)      The extension or termination of such indenture or agreement.

                  Not applicable.

         (c)      The removal or resignation of the trustee or custodian, or the
                  failure of the trustee or custodian to perform its duties,
                  obligations and functions.

                  The Company acts as custodian. There are no provisions
                  relating to the removal or resignation of the custodian or the
                  failure of the custodian to perform its duties, obligations
                  and functions.

         (d)      The appointment of a successor trustee and the procedure if a
                  successor trustee is not appointed.


                                       31
<PAGE>


                  The Variable Account has no trustee.

         (e)      The removal or resignation of the depositor, or the failure of
                  the depositor to perform its duties, obligations and
                  functions.

                  There are no provisions relating to the removal or resignation
                  of the depositor or the failure of the depositor to perform
                  its duties, obligations and functions.

         (f)      The appointment of a successor depositor and the procedure if
                  a successor depositor is not appointed.

                  There are no provisions relating to the appointment of a
                  successor depositor and the procedure if a successor depositor
                  is not appointed.

21.      (a)      State the substance of the provisions of any indenture or
                  agreement with respect to loans to security holders.

                  So long as the Policy remains in force and has a positive Net
                  Cash Value, a Policyowner may borrow money from the
                  Company at any time using the Policy as the sole security for
                  the Policy Loan. The maximum amount that may be borrowed at
                  any time is 90% of the Net Cash Value as of the end of the
                  Valuation Period during which the request for a Policy Loan is
                  received at the Home Office. The Company's claim for repayment
                  of Policy Debt has priority over the claims of any assignee or
                  other person.

                  During any time that there is outstanding Policy Debt,
                  payments made by the Policyowner will be treated first as
                  payment of outstanding Policy Debt, unless the Policyowner
                  indicates that the payment should be treated otherwise. Where
                  no indication is made, any portion of a payment that exceeds
                  the amount of any outstanding Policy Debt will be treated as a
                  premium payment.

                  When a Policy Loan is made, an amount equal to the Policy Loan
                  will be segregated within the Declared Interest Option as
                  security for the Policy Loan. If, immediately prior to the
                  Policy Loan, the Cash Value in the Declared Interest Option
                  less Policy Debt outstanding immediately prior to such Policy
                  Loan is less than the amount of such Policy Loan, the
                  difference will be transferred from the Subaccounts which have
                  Cash Value in the same proportions that the Policy's Cash
                  Value in each Subaccount bears to the Policy's total Cash
                  Value in the Variable Account. Cash Values will be determined
                  as of the end of the Valuation Period during which the request
                  for the Policy Loan is received at the Home Office.


                                       32
<PAGE>


                  Policy Loan proceeds will normally be mailed to the
                  Policyowner within seven days after receipt of a written
                  request. Postponement of a loan may take place under certain
                  circumstances.

                  Amounts segregated within the Declared Interest Option as
                  security for Policy Debt will bear interest at an effective
                  annual rate set by the Company.

                  The interest rate charged on Policy Loans is not fixed. In a
                  VUL, it will be the rate shown in the Policy on the policy
                  data page. The Company may at any time elect to change the
                  interest rate, subject to the following conditions: (i) the
                  rate may not exceed 7.4% per year in advance (which is equal
                  to an effective rate of 8%); (ii) any increase in the interest
                  rate may not exceed 1% per calendar year, and (iii) changes in
                  the interest rate may not occur more often than once in any
                  twelve-month period. In an LSVUL, the maximum annual loan
                  interest rate will be no greater than the "Published Monthly
                  Average of the Composite Yield on Seasoned Corporate Bonds" as
                  published by Moody's Investors Service, Inc. or any successor
                  thereto for the calendar month ending two months before the
                  date on which the rate is determined; or 5.5%. The Company may
                  at any time elect to change the interest rate. The Company
                  will send notice of any change in rate to the Policyowner. The
                  new rate will take effect on the Policy Anniversary coinciding
                  with or next following the date the rate is changed.

                  Interest is payable in advance at the time any Policy Loan is
                  made (for the remainder of the Policy Year) and on each Policy
                  Anniversary thereafter (for the entire Policy Year) so long as
                  there is Policy Debt outstanding. Interest payable at the time
                  a Policy Loan is made will be subtracted from the loan
                  proceeds. Thereafter, interest not paid when due will be added
                  to the existing Policy Debt and bear interest at the same rate
                  charged for Policy Loans. The amount equal to unpaid interest
                  will be segregated within the Declared Interest Option in the
                  same manner that amounts for Policy Loans are segregated
                  within the Declared Interest Option.

                  Because interest is charged in advance, any interest that has
                  not been earned will be added to the death benefit payable at
                  the Insured's death and to the Cash Value upon complete
                  surrender, and will be credited to the Cash Value in the
                  Declared Interest Option upon repayment of Policy Debt.

                  Amounts transferred from the Variable Account as security for
                  Policy Loans will no longer participate in the investment
                  performance of the Variable Account. All amounts held in the
                  Declared Interest option as security for Policy Debt will be
                  credited with interest on each Monthly Deduction Day. In a
                  VUL, interest will be credited at an effective annual rate of
                  between 4.5% and 6%; and in an LSVUL, interest will be
                  credited at an effective annual rate equal to the greater of
                  4% or the current effective loan interest rate minus no more
                  than 3%, as determined and


                                       33
<PAGE>


                  declared by the Company. No additional interest will be
                  credited to these amounts. The interest credited will remain
                  in the Declared Interest Option unless and until transferred
                  by the Policyowner to the Variable Account, but will not be
                  segregated within the Declared Interest Option as security for
                  Policy Debt. In an LSVUL, the Company may allow a loan spread
                  of 0% on the gain in a Policy in effect a minimum of ten
                  years.

                  Policy Debt equals the sum of all unpaid Policy Loans and any
                  due and unpaid policy loan interest. If Net Cash Value is
                  insufficient on a Monthly Deduction Day to cover the monthly
                  deduction, the Company will notify the Policyowner. To avoid
                  lapse and termination of the Policy without value, the
                  Policyowner must, during the Grace Period, make a premium
                  payment that, when reduced by the premium expense charge, will
                  be at least equal to three times the monthly deduction due on
                  such Monthly Deduction Day.

                  Policy Debt may be repaid in whole or in part any time during
                  the Insured's life and before the Maturity Date so long as the
                  Policy is in force. Any Policy Debt not repaid is subtracted
                  from the death benefit payable at the Insured's death, from
                  Cash Value upon complete surrender, or from the maturity
                  benefit. Upon repayment of Policy Debt, the Cash Value in the
                  Declared Interest Option securing the repaid portion of the
                  Policy Debt will no longer be segregated within the Declared
                  Interest Option as security for the Policy Debt, but will
                  remain in the Declared Interest Option unless and until
                  transferred to the Variable Account by the Policyowner.

         (b)      Furnish a brief description of any procedure or arrangement by
                  which loans are made available to security holders by the
                  depositor, principal underwriter, trustee or custodian, or any
                  affiliated person of the foregoing.

                  Proceeds of a Policy Loan will normally be mailed within seven
                  days after receipt of a written request for such loan. Payment
                  of any Policy Loan may be postponed whenever: (i) the New York
                  Stock Exchange is closed other than customary weekend and
                  holiday closings, or trading on the New York Stock Exchange is
                  restricted as determined by the Commission; (ii) the
                  Commission by order permits postponement for the protection of
                  Policyowners; (iii) an emergency exists, as determined by the
                  Commission, as a result of which disposal of securities is not
                  reasonably practicable or it is not reasonably practicable to
                  determine the value of the net assets of the Variable Account.
                  In addition, the payment of Policy Loans allocated to the
                  Declared Interest Option may be delayed for up to six months.
                  In addition, payment of loan proceeds made available as a
                  result of Cash Value derived from premiums paid by check or
                  draft may be delayed until such time as the Company is
                  satisfied that the check or draft has cleared the bank upon
                  which it is drawn.


                                       34
<PAGE>


                  SEE paragraph (a) of this Item.

         (c)      If such loans are made, furnish the aggregate amount of loans
                  outstanding at the end of the last fiscal year, the amount of
                  interest collected during the last fiscal year allocated to
                  the depositor, principal underwriter, trustee or custodian or
                  affiliated person of the foregoing and the aggregate amount of
                  loans in default at the end of the last fiscal year covered by
                  financial statements filed herewith.

                  Not applicable.

22.      State the substance of the provisions of any indenture or agreement
         with respect to limitations on the liabilities of the depositor,
         trustee or custodian, or any other party to such indenture or
         agreement.

         There is no such provision or agreement.

23.      Describe any bonding arrangement for officers, directors, partners or
         employees of the depositor or principal underwriter of the trust,
         including the amount of coverage and the type of bond.

         Additional protection for the assets of the Variable Account is
         afforded by a blanket fidelity bond issued by Chubb Group of Insurance
         Companies in the amount of $5,000,000 covering all of the officers and
         employees of the Company.

24.      State the substance of any other material provisions of any indenture
         or agreement concerning the trust or its securities and a description
         of any other material functions or duties of the depositor, trustee or
         custodian not stated in Item 10 or Items 14 to 23 inclusive.

         THE CONTRACT. The Policy is issued in consideration of the statements
         in the application and the payment of the initial premium. The Policy,
         the application, and any supplemental applications and endorsements
         make up the entire contract. In the absence of fraud, the statements
         made in an application or supplemental application will be treated as
         representations and not as warranties. No statement will void the
         Policy or be used in defense of a claim unless contained in the
         application or any supplemental application.

         INCONTESTABILITY. The Policy is incontestable, except for fraudulent
         statements made in the application or supplemental applications, after
         it has been in force during the lifetime of the Insured (or Joint
         Insureds, as applicable) for two years from the Policy Date or date of
         reinstatement. This provision does not apply to riders that provide
         disability or accidental death benefits. Any increase in Specified
         Amount will be incontestable only after it has been in force during the
         lifetime of the Insured for two years from the effective date of the
         increase.


                                       35
<PAGE>


         CHANGE OF PROVISIONS. The Company reserves the right to change the
         Policy, in the event of future changes in the federal tax law, to the
         extent required to maintain the Policy's qualification as life
         insurance under federal tax law.

         Except as provided in the foregoing paragraph, no one can change any
         part of the Policy except the Policyowner and the President, a Vice
         President, or the Secretary or Assistant Secretary of the Company. Both
         must agree to any change and such change must be in writing. No agent
         may change the Policy or waive any of its provisions.

         MISSTATEMENT OF AGE OR SEX. If any Insured's age or sex was misstated
         in the application, each benefit and any amount to be paid under the
         Policy will be adjusted to reflect the correct age and sex.

         SUICIDE EXCLUSION. If the Policy is in force and the Insured in a VUL
         (or last Joint Insured in an LSVUL) commits suicide, while sane or
         insane, within two years from the Policy Date, life insurance proceeds
         payable under the Policy will be limited to all premiums paid, reduced
         by any outstanding Policy Debt and any partial surrenders, and
         increased by any unearned loan interest. If the Policy is in force and
         the Insured commits suicide, while sane or insane, within two years
         from the effective date of any increase in Specified Amount, any
         increase in the death benefit resulting from the requested increase in
         specified amount will not be paid. Instead, the Company will refund to
         the Policyowner an amount equal to the total cost of insurance applied
         to the increase.

         ANNUAL REPORT. At least once each year, an annual report will be sent
         to each Policyowner. The report will show the current death benefit,
         the Cash Value in each Subaccount and in the Declared Interest Option,
         outstanding Policy Debt, and premiums paid, partial surrenders made,
         and charges assessed, since the last report. The report will also
         include any other information required by state law or regulation.
         Further, the Company will send the Policyowner the reports required by
         the Investment Company Act of 1940.

         NON-PARTICIPATION. The Policy does not participate in the Company's
         profits or surplus earnings. No dividends are payable.

         OWNERSHIP OF ASSETS. The Company shall have the exclusive and absolute
         ownership and control over assets, including the assets of the Variable
         Account.

         WRITTEN NOTICE. Any written notice should be sent to the Company at its
         Home Office. The notice should include the policy number and the
         Insured's full name. Any notice sent by the Company to a Policyowner
         will be sent to the address shown in the application unless an
         appropriate address change form has been filed with the Company.

         POSTPONEMENT OF PAYMENTS. The Company will usually mail the proceeds of
         complete surrenders, partial surrenders and Policy Loans within seven
         days after the Policyowner's


                                       36
<PAGE>


         signed request is received at the Home Office. The Company will
         usually mail death proceeds within seven days after receipt of Due
         Proof of Death, and maturity benefits within seven days of the
         Maturity Date. However, payment of any amount upon complete or partial
         surrender, payment of any policy loan, and payment of death proceeds
         or benefits at maturity may be postponed whenever: (a) the New York
         Stock Exchange is closed other than customary weekend and holiday
         closings, or trading on the New York Stock Exchange is restricted as
         determined by the Commission; (b) the Commission by order permits
         postponement for the protection of Policyowners; or (c) an emergency
         exists, as determined by the Commission, as a result of which disposal
         of the securities is not reasonably practicable or it is not
         reasonably practicable to determine the value of the net assets of the
         Variable Account.

         Transfers may also be postponed under these circumstances.

         Payments under the Policy which are derived from any amount paid to the
         Company by check or draft may be postponed until such time as the
         Company is satisfied that the check or draft has cleared the bank upon
         which it is drawn.

         CONTINUANCE OF INSURANCE. The insurance under a Policy will continue
         until the earlier of: (a) the end of the Grace Period following the
         Monthly Deduction Day on which the Net Cash Value or Net Surrender
         Value is less than the monthly deduction for the following Policy
         Month; (b) the date the Policyowner surrenders the Policy for its
         entire Net Cash Value (or Net Surrender Value, as applicable); (c) the
         death of the Insured (or last Joint Insured, as applicable); or (d) the
         Maturity Date.

         Any rider to a Policy will terminate on the date specified in the
         rider.

         OWNERSHIP. The Policy belongs to the Policyowner. The original
         Policyowner is the person named as owner in the application. Ownership
         of the Policy may change according to the ownership option selected as
         part of the original application or by a subsequent endorsement to the
         Policy. During the Insured's (or Joint Insureds') lifetime(s), all
         rights granted by the Policy belong to the Policyowner, except as
         otherwise provided for in the Policy.

         Special ownership rules may apply if any Insured is under legal age (as
         defined by the law of the state in which the Policy is issued) on the
         Policy Date.

         The Policyowner may assign the Policy as collateral security. The
         Company assumes no responsibility for the validity or effect of any
         collateral assignment of the Policy. No assignment will bind the
         Company unless in writing and until received by the Company at its Home
         Office. The assignment is subject to any payment or action taken by the
         Company before it received the assignment at the Home Office.


                                       37
<PAGE>


         THE BENEFICIARY. The primary Beneficiaries and contingent Beneficiaries
         are designated by the Policyowner in the application. If changed, the
         primary Beneficiary or contingent Beneficiary is as shown in the latest
         change filed with the Company. One or more primary or contingent
         Beneficiaries may be named in the application. In such case, the
         proceeds will be paid in equal shares to the survivors in the
         appropriate beneficiary class, unless requested otherwise by the
         Policyowner.

         Unless a payment option is chosen, the proceeds payable at the
         Insured's death will be paid in a lump sum to the primary Beneficiary.
         If the primary Beneficiary dies before the Insured (or last Joint
         Insured, if applicable), the proceeds will be paid to the contingent
         Beneficiary. If no Beneficiary survives the Insured (or last Joint
         Insured, if applicable), the proceeds will be paid to the Policyowner
         or the Policyowner's estate.

         CHANGING THE POLICYOWNER OR BENEFICIARY. During the Insured's life, the
         Policyowner and the Beneficiary may be changed. To make a change,
         written request must be sent to the Company at its Home Office. The
         request and the change must be in a form satisfactory to the Company
         and must actually be received and recorded by the Company. The change
         will take effect as of the date the request is signed by the
         Policyowner. The change will be subject to any payment made before the
         change is recorded by the Company. The Company may require return of
         the Policy for endorsement.

         POLICY SPLIT OPTION. In an LSVUL only, the Policyowner may split the
         Policy into two single-life insurance policies, one on each of the
         Joint Insureds, upon the occurrence of (1) divorce or annulment with
         respect to the marriage of the Joint Insureds, or (2) a change in the
         Federal Estate Tax Law. The Policyowner may elect this option subject
         to the following provisions: (a) written notification must be provided
         to the Company within 90 days after the effective date of one of the
         two events listed above; (b) each new policy will be issued for no more
         than one-half the Specified Amount of the original policy; (c) the Net
         Surrender Value will be divided and allocated in proportion to the
         Specified Amount of the new policy; (d) the Beneficiary of the original
         policy will be the beneficiary of each new policy; (e) if the Joint
         Insureds are the owners of the original policy, each will be the owner
         of their new policy; (f) the new policies will be issued based on the
         age and premium class for each Joint Insured on the effective date of
         the election of this option; (g) this option will not be available
         after the date of the first death of the Joint Insureds; and (h) the
         two single-life policies may be any single permanent life policies
         currently offered by the Company.

                                      III.

                 ORGANIZATION, PERSONNEL AND AFFILIATED PERSONS
                                  OF DEPOSITOR

ORGANIZATION AND OPERATIONS OF DEPOSITOR


                                       38
<PAGE>


25.      State the form or organization of the depositor of the trust, the name
         of the state or other sovereign power under the laws of which the
         depositor was organized and the date of organization.

         The Company is a stock life insurance company incorporated in the
         State of Iowa on October 30, 1944.

26.      (a)      Furnish the following information with respect to all fees
                  received by the depositor of the trust in connection with the
                  exercise of any functions or duties concerning securities of
                  the trust during the period covered by the financial
                  statements filed herewith.

                  Not applicable.

         (b)      Furnish the following information with respect to any fee or
                  any participation in fees received by the depositor from any
                  underlying investment company or any affiliated person or
                  investment adviser of such company.

                  Not applicable.

27.      Describe the general character of the business engaged in by the
         depositor including a statement as to any business other than that of
         depositor of the trust. If the depositor acts or has acted in any
         capacity with respect to any investment company or companies other than
         the trust, state the name or names of such company or companies, their
         relationship, if any, to the trust, and the nature of the depositor's
         activities therewith. If the depositor has ceased to act in such named
         capacity, state the date of and circumstance surrounding such
         cessation.

         The Company is principally engaged in offering life insurance and
         annuity contracts and is admitted to do business in 18
         states - Arizona, Colorado, Idaho, Iowa, Kansas, Minnesota,
         Montana, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon,
         South Dakota, Utah, Washington, Wisconsin and Wyoming.

Officials and Affiliated Persons of Depositor

28.      (a)      Furnish as at latest practicable date the following
                  information with respect to the depositor of the trust, with
                  respect to each officer, director, or partner of the
                  depositor, and with respect to each natural person directly or
                  indirectly owning, controlling or holding with power to vote
                  5% or more of the outstanding voting securities of the
                  depositor.

                    (i)  name and principal business address;

                    (ii) nature of relationship or affiliation with depositor of
                         the trust;


                                       39
<PAGE>


                    (iii) ownership of all securities of the depositor;

                    (iv) ownership of all securities of the trust;

                    (v)  other companies of which each person named above is
                         presently officer, director, or partner.

                  See answer to Item 28(b) and Item 29.

         (b)      Furnish a brief statement of the business experience during
                  the last five years of each officer, director or partner of
                  the depositor.

                  OFFICERS AND DIRECTORS OF FARM BUREAU LIFE INSURANCE COMPANY

                  Please refer to the Form S-6 registration statement filed with
                  the Securities and Exchange Commission for the Variable
                  Account for a current list of officers and directors of the
                  Company.

COMPANIES OWNING SECURITIES OF DEPOSITOR

29.      Furnish as at latest practicable date the following information with
         respect to each company which directly or indirectly owns, controls or
         holds power to vote 5% or more of the outstanding voting securities of
         the depositor: (a) name and principal business address; (b) nature of
         business; (c) ownership of all securities of the depositor.

         The Company is a wholly owned subsidiary of Iowa Farm Bureau
         Federation. Iowa Farm Bureau Federation is an Iowa not-for-profit
         corporation, the members of which are county farm bureau organizations
         and their individual members. Iowa Farm Bureau Federation is primarily
         engaged, through various divisions and subsidiaries, in the
         formulation, analysis, and promotion of programs (at local, state,
         national, and international levels) that are designed to foster the
         educational, social, and economic advancement of its members. The
         principal offices of Iowa Farm Bureau Federation are at 5400 University
         Avenue, West Des Moines, Iowa 50266.

CONTROLLING PERSONS

30.      Furnish as at latest practicable date the following information with
         respect to any person, other than those covered by Items 28, 29, and 42
         who directly or indirectly controls the depositor.

         None.

COMPENSATION OF OFFICERS AND DIRECTORS OF DEPOSITOR

COMPENSATION OF OFFICERS


                                       40
<PAGE>


31.      Furnish the following information with respect to the remuneration for
         services paid by the depositor during the last fiscal year covered by
         financial statements filed herewith:

         (a)      directly to each of the officers or partners of the depositor
                  directly receiving the three highest amounts of remuneration;

         (b)      directly to all officers or partners of the depositor as a
                  group exclusive of persons whose remuneration is included
                  under Item 31(a), stating separately the aggregate amount paid
                  by the depositor itself and the aggregate amount paid by all
                  the subsidiaries;

         (c)      indirectly or through subsidiaries to each of the officers or
                  partners of the depositor.

                  Not applicable. As of this date, meaningful allocations have
                  not been made.

COMPENSATION OF DIRECTORS

32.      Furnish the following information with respect to the remuneration for
         services, exclusive of remuneration reported under Item 31, paid by the
         depositor during the last fiscal year covered by financial statements
         filed herewith:

         (a)      the aggregate direct remuneration to directors;

         (b)      indirectly or through subsidiaries to directors.

                  Not applicable.   SEE Item 31.

COMPENSATION TO EMPLOYEES

33.      (a)      Furnish the following information with respect to the
                  aggregate amount of remuneration for services of all employees
                  of the depositor (exclusive of persons whose remuneration is
                  reported in Items 31 and 32) who received remuneration in
                  excess of $10,000 during the last fiscal year covered by
                  financial statements filed herewith from the depositor and any
                  of its subsidiaries.

                  Not applicable.   SEE Item 31.

         (b)      Furnish the following information with respect to the
                  remuneration for services paid directly during the last fiscal
                  year covered by financial statements filed herewith to the
                  following classes of persons (exclusive of those persons
                  covered by Item 33(a)): (1) Sales managers, branch managers,
                  district managers and other persons supervising the sale of
                  registrant's securities; (2) Salesmen, sales agents,
                  canvassers and other persons making solicitations but not in
                  supervisory capacity;


                                       41
<PAGE>


                  (3) Administrative and clerical employees; and (4) Others
                  (specify). If a person is employed in more than one capacity,
                  classify according to predominant type of work.

                  Not applicable.   SEE Item 31.

COMPENSATION TO OTHER PERSONS

34.      Furnish the following information with respect to the aggregate amount
         of compensation for services paid any person (exclusive of persons
         whose remuneration is reported in Items 31, 32 and 33), whose aggregate
         compensation in connection with services rendered with respect to the
         trust in all capacities exceeded $10,000 during the last fiscal year
         covered by financial statements filed herewith from the depositor and
         any of its subsidiaries.

         Not applicable.   SEE Item 31.

                                       IV.

                    DISTRIBUTION AND REDEMPTION OF SECURITIES

DISTRIBUTION OF SECURITIES

35.      Furnish the names of the states in which sales of the trust's
         securities (A) are currently being made, (B) are presently proposed to
         be made, and (C) have been discontinued, indicating by appropriate
         letter the status with respect to each state.

         VUL sales are currently being made in the states of Arizona, Colorado,
         Idaho, Iowa, Minnesota, Montana, Nebraska, New Mexico, North Dakota,
         Oklahoma, South Dakota, Utah, Wisconsin and Wyoming. No LSVUL sales are
         currently being made, but it is proposed that this policy be made
         available for sale in the same states.

36.      If sales of the trust's securities have at any time since January 1,
         1936 been suspended for more than a month, describe briefly the reasons
         for such suspension.

         Not applicable.

37.      (a)      Furnish the following information with respect to each
                  instance where subsequent to January 1, 1937, any federal or
                  state governmental officer, agency, or regulatory body denied
                  authority to distribute securities of the trust, excluding a
                  denial which was merely a procedural step prior to any
                  determination by such officer, etc. and which denial was
                  subsequently rescinded.

                  (1)      Name of officer, agency or body.


                                       42
<PAGE>


                  (2)      Date of denial.

                  (3)      Brief statement of reason given for revocation.

                           Not applicable.

         (b)      Furnish the following information with regard to each instance
                  where, subsequent to January 1, 1937, the authority to
                  distribute securities of the trust has been revoked by any
                  federal or state governmental officer, agency or regulatory
                  body.

                  Not applicable.

38.      (a)      Furnish a general description of the method of distribution of
                  securities of the trust.

                  The Policy will be sold by individuals who, in addition to
                  being licensed as life insurance agents for the Company, are
                  also registered representatives of ET Marketing, the principal
                  underwriter of the Policies. ET Marketing is registered with
                  the Securities and Exchange Commission under the Securities
                  Exchange Act of 1934 and is a member of the National
                  Association of Securities Dealers, Inc.

         (b)      State the substance of any current selling agreement between
                  each principal underwriter and the trust or the depositor,
                  including a statement as to the inception and termination
                  dates of the agreement, any renewal and termination
                  provisions, and any assignment provisions.

                  The Company has entered into an agreement with ET Marketing,
                  the principal underwriter, pursuant to which the Company will
                  pay commissions for services in distributing the Policy.

         (c)      State the substance of any current agreements or arrangements
                  of each principal underwriter with dealers, agents, salesmen,
                  etc. with respect to commissions and overriding commissions,
                  territories, franchises, qualifications and revocations. If
                  the trust is the issuer of periodic payment plan certificates,
                  furnish schedules of commissions and the bases thereof. In
                  lieu of a statement concerning schedules of commissions, such
                  schedules of commissions may be filed as Exhibit A(3)(c).

                  SEE Exhibit A (3) (c).

INFORMATION CONCERNING PRINCIPAL UNDERWRITER


                                       43
<PAGE>


39.      (a)      State the form of organization of each principal
                  underwriter of securities of the trust, the name of the
                  state or other sovereign power under the laws of which each
                  underwriter was organized and the date of organization.

                  ET Marketing, the principal underwriter of the Policy, is a
                  corporation incorporated on May 7, 1970 under the laws of
                  Delaware.

         (b)      State whether any principal underwriter currently distributing
                  securities of the trust is a member of the National
                  Association of Securities Dealers, Inc.

                  ET Marketing is a member of the National Association of
                  Securities Dealers, Inc.

40.      (a)      Furnish the following information with respect to all fees
                  received by each principal underwriter of the trust from the
                  sale of securities of the trust and any other functions in
                  connection therewith exercised by such underwriter in such
                  capacity or otherwise during the period covered by the
                  financial statements filed herewith.

                  Not applicable.

         (b)      Furnish the following information with respect to any fee or
                  any participation in fees received by each principal
                  underwriter from any underlying investment company or any
                  affiliated person or investment adviser of such company:

                  (1)      The nature of such fee or participation.

                  (2)      The name of the person making payment.

                  (3)      The nature of the services rendered in consideration
                           for such fee or participation.

                  (4)      The aggregate amount received during the last fiscal
                           year covered by the financial statements filed
                           herewith.

                           No fees have yet been paid.

41.      (a)      Describe the general character of the business engaged in by
                  each principal underwriter, including a statement as to any
                  business other than the distribution of securities of the
                  trust. If a principal underwriter acts or has acted in any
                  capacity with respect to any investment company or companies
                  other than the trust, state the name or names of such company
                  or companies, their relationship, if any, to the trust and the
                  nature of such activities. If a principal underwriter has
                  ceased to act in such named capacity, state the date of and
                  the circumstances surrounding such cessation.


                                       44
<PAGE>


                  ET Marketing acts as principal underwriter of the Policies. ET
                  Marketing also underwrites or distributes other variable
                  insurance policies or other securities.

         (b)      Furnish as at latest practicable date the address of each
                  branch office of each principal underwriter currently selling
                  securities of the trust and furnish the name and residence
                  address of the person in charge of office.

                  Not applicable.

         (c)      Furnish the number of individual salesmen of each principal
                  underwriter through whom any of the securities of the trust
                  were distributed for the last fiscal year of the trust covered
                  by the financial statements filed herewith and furnish the
                  aggregate amount of compensation received by such salesmen in
                  such year.

                               salesmen for VUL, $                compensation
                  ------------                    ---------------
                  received for VUL.
                  Not applicable for LSVUL.

42.      Furnish as at latest practicable date the following information with
         respect to each principal underwriter currently distributing securities
         of the trust and with respect to each of the officers, directors or
         partners of such underwriter: (a) name and principal business address;
         (b) position with principal underwriter; (c) ownership of securities of
         the trust.

         Stephen M. Morain, Senior Vice President, General Counsel & Manager
         William J. Oddy, Chief Operating Officer & Manager
         Thomas R. Gibson, Chief Executive Office & Manager
         James W. Noyce, Chief Financial Officer & Manager
         Timothy J. Hoffman, Vice President
         Dennis M. Marker, Investment Vice President, Administration, Secretary
         & Manager
         Thomas E. Burlingame, Manager
         F. Walter Tomenga, Manager
         Lynn E. Wilson, Manager
         Lou Ann Sandburg, Vice President, Investments, Assistant Treasurer &
         Manager
         Robert A. Simons, Senior Counsel - Investments
         James P. Brannen, Controller & Vice President
         Sue A. Cornick, Sr. Market Conduct & Mutual Funds Vice President &
         Ass't Secretary
         Kristi Rojohn, Director, Investment Compliance & Assistant Secretary
         Elaine A. Followwill, Compliance Assistant & Assistant Secretary
         Roger F. Grefe, Investment Management Vice President
         Robert Rummelhart, Fixed Income Vice President
         Charles T. Happel, Portfolio Manager
         Laura Kellen Beebe, Portfolio Manager
         Larry J. Patterson, Vice President


                                       45
<PAGE>


         The sale of the LSVUL Policy has not yet commenced.

43.      Furnish, for the last fiscal year covered by the financial statements
         filed herewith, the amount of brokerage commissions received by any
         principal underwriter who is a member of a national securities exchange
         and who is currently distributing the securities of the trust or
         effecting transactions for the trust in the portfolio securities of the
         trust.

         $                   commissions received for VUL.
          -------------------
         Not applicable for LSVUL.

OFFERING PRICE OR ACQUISITION VALUATION OF SECURITIES OF THE TRUST

44.      (a)      Furnish the following information with respect to the
                  method of valuation used by the trust for purposes of
                  determining the offering price to the public of securities
                  issued by the trust or the valuation of shares or interests in
                  the underlying securities acquired by the holder of a periodic
                  payment plan certificate:

                  (1)      The source of quotations used to determine the value
                           of portfolio securities.

                           Fund shares are valued at the net asset value per
                           share as supplied to the Company by the Fund or its
                           agent.

                  (2)      Whether opening, closing, bid, asked or any other
                           price is used.

                           SEE Items 44(a)(1) and 16.

                  (3)      Whether price is as of the day of sale or as of any
                           other time.

                           SEE Item 16.

                  (4)      A brief description of the methods used by registrant
                           for determining other assets and liabilities
                           including accrual for expenses and taxes (including
                           taxes on unrealized appreciation).

                           The assets of the Variable Account and liabilities
                           (such as charges against the Variable Account) are
                           valued in accordance with generally accepted
                           accounting principles on an accrual basis. Because of
                           its current tax status, the Company does not expect
                           to incur any federal income tax liabilities that
                           would be chargeable to the Variable Account, and the
                           Company does not intend to make a charge for federal
                           income taxes. The Company may, however, incur state
                           and local taxes (in addition to premium taxes) in
                           several states. At present, these taxes are not
                           significant. If there is a


                                       46
<PAGE>


                           material change in state or local tax laws, charges
                           for such taxes, if any, attributable to the Variable
                           Account may be made.

                  (5)      Other items which registrant adds to the net asset
                           value in computing offering price of its securities.

                           Not applicable.

                  (6)      Whether adjustments are made for fractions:

                           (i)      before adding distributor's compensation
                                    (load); and

                           (ii)     after adding distributor's compensation
                                    (load).

                           Not applicable because the Variable Account does not
                           compute per-unit values and sales loads in the manner
                           presupposed by this Item and Item 44(b).

                           Appropriate adjustments will be made for fractions in
                           all computations.

         (b)      Furnish a specimen schedule showing the components of the
                  offering price of the trust's securities as at the latest
                  practicable date.

                  The Company may require the Policyowner to pay an initial
                  premium that, when reduced by the premium expense charge, will
                  be sufficient to pay the monthly deduction for the first
                  policy month.

         (c)      If there is any variation in the offering price of the trust's
                  securities to any person or classes of persons other than
                  underwriters, state the nature and amount of such variation
                  and indicate the person or classes of persons to whom such
                  offering is made.

                  The Company does not require premium payments of a fixed
                  amount at designated intervals for a specified time period.
                  The Policyowner may, subject to the limitations set forth in
                  Item 10(i), pay premiums at any frequency and in any amount.
                  Nonetheless, Policyowners will need to pay sufficient premiums
                  to maintain adequate Cash Value to pay monthly charges,
                  including the cost of insurance. The cost of insurance will
                  vary, depending upon the Insured's age, sex and premium class.
                  In addition, there will be additional charges if additional
                  insurance benefits are elected. Thus, for the Policy to remain
                  in force, a Policyowner will need to take the cost of
                  insurance, as well as other factors such as investment
                  performance, into consideration in determining the amount and
                  frequency of premium payments.


                                       47
<PAGE>


45.      Furnish the following information with respect to any suspension of the
         redemption rights of the securities issued by the trust during the
         three fiscal years covered by the financial statements filed herewith.

         Not applicable.

REDEMPTION VALUATION OF SECURITIES OF THE TRUST

46.      (a)      Furnish the following information with respect to the
                  method of determining the redemption or withdrawal valuation
                  of securities issued by the trust:

                  (1)      The source of quotations used to determine the value
                           of portfolio securities.

                           SEE Item 44(a)(1).

                  (2)      Whether opening, closing, bid, asked or any other
                           price is used.

                           SEE Item 44(a)(2).

                  (3)      Whether price is as of the day of sale or as of any
                           other time.

                           The price is as of the end of the Valuation Period
                           during which the surrender request is received at the
                           Company's Home Office.

                  (4)      A brief description of the methods used by registrant
                           for determining other assets and liabilities
                           including accrual for expenses and taxes (including
                           taxes on unrealized appreciation).

                           SEE Items 44(a)(4) and 18(c).

                  (5)      Other items which registrant deducts from the net
                           asset value in computing redemption value of its
                           securities:

                           SEE Answer to Item 10(c).

                  (6)      Whether adjustments are made for fractions.

                           Not applicable.

         (b)      Furnish a specimen schedule showing the components of the
                  redemption price to the holders of the trust's securities as
                  at latest practicable date.


                                       48
<PAGE>


                  A surrender charge equal to the lesser of $25 or 2% of the
                  amount partially or fully surrendered will apply under a VUL.
                  (This same calculation will be considered for the partial
                  withdrawal fee in and LSVUL). In an LSVUL, a surrender charge
                  will apply to any surrender during the first ten Policy Years,
                  as well as during the first ten years following an increase in
                  Specified Amount.

PURCHASE AND SALE OF INTERESTS IN UNDERLYING SECURITIES FROM AND TO SECURITY
HOLDERS

47.      Furnish a statement as to the procedure with respect to the maintenance
         of a position in the underlying securities or interests in the
         underlying securities, the extent and nature thereof and the person who
         maintains such a position. Include a description of the procedure with
         respect to the purchase of underlying securities or interests in
         underlying securities from security holders who exercise redemption or
         withdrawal rights and the sale of such underlying securities and
         interests in the underlying securities to other security holders. State
         whether the method of valuation of such underlying securities or
         interests in underlying securities differs from that set forth in Items
         44 and 46. If any item of expenditure included in the determination of
         the valuation is not or may not actually be incurred or expended,
         explain the nature of such item and who may benefit from the
         transaction.

         Shares of the Fund are purchased at net asset value. Shares of the Fund
         will be issued only to the Company, its affiliates and non-affiliated
         life insurance companies for investment of the assets of separate
         accounts that hold assets from the sale of variable insurance products,
         and will not be sold directly to the general public. The Company will
         redeem sufficient shares of the Fund to pay certain life insurance
         proceeds, benefits at maturity, or surrender proceeds, or for other
         purposes contemplated by the Policy.

                                       V.

                       INFORMATION CONCERNING THE TRUSTEE
                                  OR CUSTODIAN

48.      Furnish the following information as to each trustee or custodian of
         the trust:

         (a)      Name and principal business address.

         (b)      Form of organization.

         (c)      State or other sovereign power under the laws of which the
                  trustee or custodian was organized.

         (d)      Name of governmental supervising or examining authority.


                                       49
<PAGE>


                  The Company acts as custodian and holds the assets of the
                  Variable Account and maintains records of all purchases and
                  redemptions of shares of the Investment Options held by the
                  Variable Account. The assets are kept physically segregated
                  and held separate and apart from the Company's General
                  Account. SEE ALSO Item 2.

49.      State the basis for payment of fees or expenses of the trustee or
         custodian for services rendered with respect to the trust and its
         securities, and the aggregate amount thereof for the last fiscal year.
         Indicate the person paying such fees or expenses. If any fees or
         expenses are prepaid, state the unearned amount.

         Not applicable.

50.      State whether the trustee or custodian or any other person has or may
         create a lien on the assets of the trust, and if so, give full
         particulars, outlining the substance of the provisions of any indenture
         or agreement with respect thereto.

         The assets of the Variable Account are not chargeable with liabilities
         arising out of any other business that the Company may conduct. The
         assets of the Variable Account are available to cover the general
         liabilities of the Company only to the extent that assets in the
         Variable Account exceed liabilities arising under the Policy. The
         income, capital gains, and capital losses of each Subaccount are
         credited to or charged against the assets held in that Subaccount in
         accordance with the terms of the Policy.

                                       VI.

                       INFORMATION CONCERNING INSURANCE OF
                              HOLDERS OF SECURITIES

51.      Furnish the following information with respect to insurance of holders
         of securities:

         (a)      The name and address of the insurance company.

                  The name and address of the Company are set forth in the
                  Answer to Item 2.

         (b)      The types of Policies and whether individual or group
                  Policies.

                  The VUL is a flexible premium variable life insurance policy
                  issued on an individual basis. The LSVUL is a flexible premium
                  last survivor variable life insurance policy issued on an
                  individual basis.

         (c)      The types of risks insured and excluded.


                                       50
<PAGE>


                  The Company assumes the risk that the deductions made for
                  mortality risks will prove inadequate to cover actual
                  insurance costs. The Company also assumes the risk that
                  deductions for expenses may be inadequate. See Item 10(i).

         (d)      The coverage of the Policies.

                  The minimum Specified Amount is stated in each Policy. Death
                  proceeds will be reduced by any outstanding Policy Debt and
                  any due and unpaid monthly deductions, and increased by any
                  unearned loan interest and any premiums paid after the date of
                  death. See Paragraph (c) of this Item.

         (e)      The Beneficiaries of such Policies and the uses to which the
                  proceeds of Policies must be put.

                  The recipient of the benefits of the insurance undertakings
                  described in the Answer to Items 10(i) and 51(c) is either the
                  Policyowner or the primary Beneficiary or contingent
                  Beneficiary specified in the Policy. There are no restrictions
                  on the use of the proceeds other than those established by the
                  Policyowner.

         (f)      The terms and manners of cancellation and of reinstatement.

                  The insurance undertakings described in the Answer to Item
                  51(c) are an integral part of the Policy and may not be
                  terminated while the Policy remains in force.

         (g)      The method of determining the amount of premiums to be paid by
                  holders of securities.

                  SEE Answers to Items 13(a) and 13(e) for the amount of charges
                  imposed. See Items 10(i) and 44(c) for the manner in which the
                  premium is determined.

         (h)      The amount of aggregate premiums paid to the insurance company
                  during the last fiscal year.

                  Not applicable.

         (i)      Whether any person other than the insurance company receives
                  any part of such premiums, the name of each such person and
                  the amounts involved, and the nature of the services rendered
                  therefor.

                  No person other than the Company receives any part of the
                  amounts deducted for assumption of mortality and expense
                  risks.


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<PAGE>


         (j)      The substance of any other material provisions of any
                  indenture or agreement of the trust relating to insurance.

                  None.

                                      VII .

                              POLICY OF REGISTRANT

52.      (a)      Furnish the substance of the provisions of any indenture or
                  agreement with respect to the conditions upon which and the
                  method of selection by which particular portfolio securities
                  must or may be eliminated from assets of the trust or must or
                  may be replaced by other portfolio securities. If an
                  investment adviser or other person is to be employed in
                  connection with such selection, elimination or substitution,
                  state the name of such person, the nature of any affiliation
                  to the depositor, trustee or custodian, and any principal
                  underwriter, and the amount of remuneration to be received for
                  such services. If any particular person is not designated in
                  the indenture or agreement, describe briefly the method of
                  selection of such person.

                  SEE Answers to Items 10(g) and 10(h) as regards the Company's
                  right to substitute any other investment for shares of any
                  Portfolio of the Fund.

         (b)      Furnish the following information with respect to each
                  transaction involving the elimination of any underlying
                  security during the period covered by the financial statements
                  filed herewith.

                  Not applicable.

         (c)      Describe the Policy of the trust with respect to the
                  substitution and elimination of the underlying securities of
                  the trust with respect to:

                  (1)      the grounds for elimination and substitution;

                  (2)      the type of securities which may be substituted;

                  (3)      whether the acquisition of such substituted security
                           or securities would constitute the concentration of
                           investment in a particular industry or group of
                           industries or would conform to a Policy of
                           concentration of investment in a particular industry
                           or group of industries;

                  (4)      whether such substituted securities may be the
                           securities of another investment company; and


                                       52
<PAGE>


                  (5)      the substance of the provisions of any indenture or
                           agreement which authorize or restrict the Policy of
                           the registrant in this regard.

                           SEE Answer to Items 10(g) and 10(h).

         (d)      Furnish a description of any policy (exclusive of policies
                  covered by paragraphs (a) and (b) herein) of the trust which
                  is deemed a matter of fundamental policy and which is elected
                  to be treated as such.

                  None.

53.      (a)      State the taxable status of the trust.

                  The Company does not expect to incur any income tax upon the
                  earnings or the realized capital gains attributable to the
                  Variable Account. Based upon these expectations, no charge is
                  being made currently to the Variable Account for federal
                  income taxes which may be attributable to the Variable
                  Account. If, however, the Company determines that it may incur
                  such taxes, it may assess a charge for those taxes from the
                  Variable Account.

                  The Company may also incur state and local taxes (in addition
                  to premium taxes) in several states. At present, these taxes
                  are not significant. If there is a material change in state or
                  local tax laws, charges for such taxes, if any, attributable
                  to the Variable Account may be made.

         (b)      State whether the trust qualified for the last taxable year as
                  a regulated investment company as defined in Section 851 of
                  the Internal Revenue Code of 1954, and state its present
                  intention with respect to such qualifications during the
                  current taxable year.

                  Not applicable. SEE Answer to Item 53(a).

                                      VIII.

                      FINANCIAL AND STATISTICAL INFORMATION

54.      If the trust is not the issuer of periodic payment plan certificates,
         furnish the following information with respect to each class or series
         of its securities.

         Not applicable.

55.      If the trust is the issuer of periodic payment plan certificates, a
         transcript of a hypothetical account shall be filed in approximately
         the following form on the basis of the certificate calling for the
         smallest amount of payments. The schedule shall cover a certificate of
         the


                                       53
<PAGE>


         type currently being sold assuming that such certificate had been sold
         at a date approximately ten years prior to the date of registration or
         at the approximate date of organization of the trust.

         Not applicable.

56.      If the trust is the issuer of periodic payment plan certificates,
         furnish by years for the period covered by the financial statements
         filed herewith in respect of certificates sold during each period, the
         following information for each fully paid type and each installment
         payment type of periodic payment plan certificate currently being
         issued by the trust.

         Not applicable.

57.      If the trust is the issuer of periodic payment plan certificates,
         furnish by years for the period covered by the financial statements
         filed herewith the following information for each installment payment
         type of periodic payment plan certificate currently being issued by the
         trust.

         Not applicable.

58.      If the trust is the issuer of periodic payment plan certificates,
         furnish the following information for each installment payment type of
         periodic payment plan certificate outstanding as at the latest
         practicable date.

         Not applicable.

59.      Financial statements:

         FINANCIAL STATEMENTS OF THE TRUST

         Financial statements will be contained in a post-effective amendment to
         the registration statement for the Policy on Form S-6 filed under the
         Securities Act of 1933. They are incorporated herein by reference.

         FINANCIAL STATEMENTS OF THE DEPOSITOR

         The financial statements of the Company will be contained in a
         post-effective amendment to the registration statement on Form S-6
         filed by the Registrant pursuant to the Securities Act of 1933. They
         are incorporated herein by reference.

                                       IX.

                                    EXHIBITS


                                       54
<PAGE>


         The required exhibits to the Farm Bureau Life Variable Account
registration statement on Form S-6 are incorporated by reference.

                                    SIGNATURE

         Pursuant to the requirements of the Investment Company Act of 1940 the
depositor of the registrant has caused this registration statement to be duly
signed on behalf of the registrant in the City of West Des Moines, State of Iowa
on February 28, 2000.

                               FARM BUREAU LIFE VARIABLE ACCOUNT

                               (Name of registrant)

                               BY:      FARM BUREAU LIFE INSURANCE COMPANY

                                        (Name of depositor)

                               By:  _/s/ Edward M. Wiederstein__

                               (Print name) _Edward M. Wiederstein_
                               (Title)           _President & Director___

                                        Farm Bureau Life Insurance Company


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